“Later Acts of Parliament impliedly repeal earlier conflicting statutory provisions.”
Ellen Street Estates challenged a compulsory purchase order under the Housing Act 1925, arguing that acquisition procedures in the Acquisition of Land Act 1919 should apply. The 1919 Act contained more protective procedural requirements than the later 1925 Act.
Whether the procedural protections in the Acquisition of Land Act 1919 remained binding despite the subsequent Housing Act 1925 containing different provisions.
The Court of Appeal held that the Housing Act 1925 impliedly repealed the conflicting provisions of the 1919 Act. Ellen Street Estates' challenge failed.
This case established the fundamental constitutional principle of implied repeal in UK law. It demonstrates parliamentary sovereignty by showing that Parliament cannot bind its successors and that later Acts automatically override conflicting earlier provisions.
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OSCOLA Citation
Ellen Street Estates v Minister of Health [1934] 1 KB 590
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