serious invasion of the current owner's proprietary rights. Nevertheless compulsory purchase orders have frequently been used to acquire land that is passed back to a private owner, including in Alliance Spring Ltd v First Secretary where homes in Islington were purchased to build the Emirates stadium for Arsenal Football Club. By contrast, in James v United Kingdom, Gerald Grosvenor, 6th Duke of Westminster, the inherited owner of most of Mayfair and Belgravia, contended that leaseholders' right to buy had violated their right to property in ECHR Protocol 1, article 1. The European Court of Human Rights ruled that the Leasehold Reform Act 1967, which allowed tenants to purchase properties from their private landlords, was within a member state's margin of appreciation. It was competent for a member state to regulate property rights in the public interest. Cases and statutes Land Clauses Consolidation Act 1845, removed the need for special private Acts for compulsory purchases driven by the railways Inclosure Act 1845, established Inclosure Commissioners to hear petitions for compulsory purchase and development Housing of the Working Classes Act 1885 Housing of the Working Classes Act 1890 Attorney-General v Great Eastern Railway Company (1880) 5 App Cas 473, 478 Ayr Harbour Trustees v Oswald (1883) 8 App Cas 623 Attorney-General v Manchester Corporation [1906] 1 Ch 643 Attorney-General v De Keyser's Royal Hotel Ltd [1920] AC 508 Stourcliffe Estates Co Ltd v Bournemouth Corporation [1910] 2 Ch 12 Defence of the Realm (Acquisition of Land) Act 1916 Acquisition of Land (Assessment of Compensation) Act 1919 Acquisition of Land (Authorisation Procedure) Act 1946 Burmah Oil Co Ltd v Lord Advocate [1965] AC 75, 115. Lord Radcliffe: "The Crown has never claimed or sought to exercise in time of peace a right to take land except by agreement or under statutory power." Prest v Secretary of State for Wales (1982) 81 LGR 193. Lord Denning MR: "It is clear that no minister or public authority can acquire any land compulsorily except the power to do so be given by Parliament: and Parliament only grants it, or should only grant it, when it is necessary in the public interest. In any case, therefore, where the scales are evenly balanced – for or against compulsory acquisition – the decision – by whomsoever it is made – should come down against compulsory acquisition. I regard it as a principle of our constitutional law that no citizen