Goldsbrough & Swart v CA Property Management – RROs Apply to Property Managers Too [2019]

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Court: Upper Tribunal (Lands Chamber)
Date: 2019
Type: RRO – Definition of Landlord in Rent-to-Rent Arrangements

Background:

Tenants Mr. Goldsbrough and Mr. Swart applied for Rent Repayment Orders against CA Property Management Ltd, the company that managed the unlicensed HMO they lived in.
The issue was whether CA Property Management Ltd could be liable, given that they weren’t the legal owner or original landlord.

Legal Issue:

Can an RRO be made against a property manager or rent-to-rent operator, rather than the owner?

Decision:

The Tribunal held that:

The term “landlord” in the context of RROs includes anyone who is in control or management of the property.
CA Property Management Ltd was found to be effectively acting as landlord, and thus liable.
Tenants can pursue whichever party fits the legal role of “landlord”, not just the owner listed on the land registry.

Legal Impact:

Rent-to-rent companies and property managers can be held liable under RROs.
This ruling expanded tenant protection and closed a major loophole.
It’s now easier for tenants to enforce their rights even in complex rental chains.

Links:

Goldsbrough & Swart v CA Property Management

Apply for a Rent Repayment Order (RRO1)

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