Trespass to Land
Trespass to Land (Pencerobohan Terhadap Tanah)
Definition of Trespass to Land
Ownership of Land (s. 5 NLC) includes:
Surface of the earth
Earth below the surface
All vegetation or natural products
All things attached or fastened to the earth
Water-covered land
Deliberate and Direct Invasion: Any unreasonable interference with land is actionable per se, regardless of damage.
What Constitutes Trespass:
Entering land in possession of the plaintiff (P)
Remaining on such land
Placing or projecting any object onto the land without lawful justification
Elements of Trespass
Mental State of the Defendant (D):
Intention to trespass
Voluntary entry
Foreseeable interference with P’s land
Interference:
Entering into land owned by P
Remaining on P’s land
Placing objects on P’s land
Interfering with airspace
Interfering under the surface of the land
Case Law: Gregory v Piper (1820)
Facts:
P owned a pub with a stable accessed through back gate via Old King’s Yard.
D owned surrounding property and obstructed P’s access by placing rubbish near the stable-yard.
Issues:
Can a master be liable for trespass due to a servant's actions?
D claimed he was not liable as he instructed the laborer not to obstruct the wall, attributing trespass to the laborer's negligence.
Decision/Outcome:
A master is liable for servant actions in executing their orders with ordinary care.
D held liable for trespass due to foreseeable results of the servile act.
Special Situations in Trespass
Trespass to Highways
Case: Hickman v Maisey (1900)
Issue: Is observing from the highway reasonable?
Question of lawful use of the highway and who qualifies as a trespasser.
Trespass to Air Space
Rights in Airspace: Does a landowner have absolute rights?
Case Law: Lord Bernstein of Leigh v Skyviews & General Ltd (1978)
Aerial photography without consent claimed as trespass.
Ruling: No trespass as property rights in airspace extend only to reasonable heights necessary for enjoyment of land (s. 44 NLC).
Important Cases in Air Space Trespass
Gifford v Dent (1926): Advertising sign projecting onto a forecourt constituted trespass.
Kelsen v Imperial Tobacco (1957): Signage that projected over leased property led to injunction.
Anchor Brewhouse v Berkley House (1987): Obstructive crane also viewed under trespass as it invaded necessary airspace.
Trespass Ab Initio
Defined as unauthorized actions that abuse lawful entry authority.
Case: Six Carpenters Case (1610) elaborated on liabilities of entry under various conditions.
Defenses to Trespass
Necessity:
Situations dealing with urgent peril (e.g., Rigby v Chief Constable of Northamptonshire).
Involuntary Intrusion:
Actions done not voluntarily (e.g., Smith v Stone).
License:
Permission to enter land can be express, implied, or contractual. Exceeding a license may lead to trespass.
Rights of Entry:
Personal rights allowing it through common law or easements.
Damages for Trespass to Land
Types of Damages:
Diminution in value
Costs for reasonable reinstatement
Consideration of loss of use, emotional distress, and physical damage.