apply to the UK Supreme Court. His main claim was that Section 72 is incompatible with his property rights, the rights guaranteed to him by Article 1 of the European Convention on Human Rights. The Supreme Court unanimously allowed the appeal. It found that Mr. Salvesen's A1P1 rights were violated by section 72(10) of the 2003 Act and that the provision was outside the legislative competence of the Scottish Parliament under the Scotland Act 1998. Community Empowerment (Scotland) Act 2015 The Community Empowerment (Scotland) Act 2015, marked the first major piece of land reform legislation to be passed under the SNP government. Its provisions covered different areas pertaining to community empowerment and public participation in policy and planning, including several related directly to land. The most important of these was the extension of the Community Right to Buy to communities of any size, including, for the first time, those in urban areas. It also introduced a new community right to buy land which is abandoned, neglected or causing harm to the environmental wellbeing of the community. Similar to the 2003 Act's crofting community right to buy, this new right does not require a willing seller. Rather, Scottish ministers may compel a landowner to sell to communities with a registered interest, if they deem the sale likely to contribute to sustainable local development. Further provisions granted community bodies the right to request to purchase, lease, manage or use land and buildings held by local authorities, Scottish ministers and other Scottish public bodies, of which relevant authorities are required to create and maintain a publicly available register. The Act reformed Common Good Property, requiring local authorities to establish and maintain registers of all common good property held by them and to inform and consult local community bodies before any change of use or disposal of common good property. Allotments, updates and simplifies legislation on allotments. It also set a requirement for local authorities to take steps to provide allotments should waiting lists exceed certain lengths and strengthened protections for allotments, regulated rents and allowed tenants to sell food produced on allotments on a not for profit basis. The act required that local authorities develop food growing strategies, including the identification of land that may be used as allotment sites or potential land for community cultivation. It has been found that the Scottish approach to community empowerment and localism marks an example of