Tag Archive for 'housing act 2004'

Tenancy Deposit Protection on Sale and Leaseback

Published
by
David Smith
on 29/01/2010
in Assured Shorthold tenancy, FLW case note and Possession
. 5 Comments

UK Housing Alliance (North West) Ltd v Michael John Francis, Grimsby County Court, 18 June 2009, unreported

An interesting case this involving issues of tenancy deposit protection, contractual penalties and the Unfair Terms in Consumer Contract Regulations 1999.

UK purchased a house in Grimsby from F in October 2007. They let it back to him on an Assured Shorthold Tenancy for a term of ten years at a rental of £520.83 pcm with annual increases of 5%. The purchase price was £125,000 to be paid in two tranches – the first, in the sum of £87,500 to be paid on completion while the second, of £37,500, on the giving up of possession at the end of the 10 year term. F would not receive the final payment if UK terminated the tenancy under their rights to do so or if he terminated it himself during the first 6 years. If F terminated after that point he would receive a percentage of the final sum on a sliding scale. F fell into arrears and possession proceedings were taken under the usual grounds as set out in Schedule II of the Housing Act 1988. After several adjournments the matter eventually came before Ms Recorder Stocken.

F, through Counsel, advanced three arguments:

  1. The final payment constituted a tenancy deposit as defined by s213 of the Housing Act 2004.
  2. The ability to withhold the final payment was a contractual penalty and was therefore unenforceable under the principles laid down in Dunlop Pneumatic Tyre Co Ltd v New Garage and Motor Co Ltd [1914] UKHL 1.
  3. The provisions of the agreement were unfair pursuant to the Unfair Terms in Consumer Contracts Regulations 1999

To work in reverse order. The Recorder was satisfied that all the terms of the agreement were in plain language and further found that F had been legally represented at the time of entering into the agreement. She was not, therefore, prepared to find the agreement to be unfair.
The Recorder also did not accept that the power to withhold the final payment constituted an unenforceable penalty. She found that the amount of the final payment was similar to the rent that would have been payable in the last four years of the tenancy and therefore found the final payment to be a reasonable estimate of loss and not a penalty.
Turning to the deposit point. The Recorder considered the wording of s212 and particularly the definition of a deposit as:

money intended to be held (by the landlord or otherwise) as security for—
(a) the performance of any obligations of the tenant, or
(b) the discharge of any liability of his

F argued that the deposit was paid in ‘money’s worth’ by the holding back of the final payment and that this final payment was designed as security for the tenant paying his rent and keeping to the terms of the tenancy. The Recorder did not accept this. She found that the final payment could be lost not just through failure to keep to the terms of the tenancy but also by the agreed right of F to terminate the lease after 6 years. After that date the deposit would also, in effect, change in value as F became entitled to receive more of it after termination. Further, the agreement contained no mention of the deposit. Finally sections 213 and 214 of the Act make mention of the deposit having been paid and repaid. The Recorder was not prepared to accept that monies had, in fact, been paid and considered that the attempt to define the final payment in this way was a “strain of the language”.

F accordingly had a possession order made against him. However, permission to appeal was granted and we understand that this matter is to come before the Court of Appeal on the 8th or 9th of February 2010 making it the first tenancy deposit matter to reach that Court.

[by NL - our thanks to Neil Wylie, Counsel for the Defendant/Appellant for letting us know about this case.]

[For all tenancy deposit case posts click here]

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HMO Planning Changes and a Consultation

Published
by
David Smith
on 29/01/2010
in FLW article and Regulation and planning
. 2 Comments

The Department of Communities and Local Government yesterday published a response on their website to a consultation on planning responses to HMOs which was launched back in May 2009.

Briefly, there is concern that certain areas, principally where there are a lot of students are becoming dominated by HMOs. The current powers to control HMOs under Part 2 of the Housing Act 2004 provide limited scope for dealing with this at is not permissible to refuse a licence for an HMO on the basis that there are too many HMOs in the immediate area. The original consultation proposed a number of ways to resolve this issue, centering around an alteration to planning categories.

Ultimately, the intended resolution involves creating a new planning category specifically for HMOs and defining it in accordance with the definition given by s254 of the Housing Act 2004. Put simply, properties rented to three or more individuals who do not form one household (three sharers in other words) will form a separate planning category and it will be necessary to obtain planning permission for these lets.

The new planning category will be brought into existence on 6 April 2010 by an amendment to the Town and Country Planning (Use Classes) Order 1987.

Separately, a short, 12 week, consultation has been launched to alter the method by which permissions are granted for additional and selective licensing under parts 2 and 3 of the Housing Act 2004 respectively. Additional licensing allows for local authorities to license HMOs other than those prescribed for mandatory licensing. About 12 local authorities do this across England. Selective licensing allows for the licensing on non-HMO landlords in areas of low housing demand which also have problems with anti-social behavior. 10 local authorities in England currently have consent to operate selective licensing schemes. The permission to operate additional and selective licensing is a devolved competency in Wales and so this consultation has no application there.

The current process requires each local authority to carry out a consultation process in its area and then seek consent from the Secretary of State to actually carry through the new licensing designation. What is proposed is to grant a blanket permission for additional and selective licensing in England, thereby removing the need for the Secretary to grant consent in each case. Each local authority will still need to carry out a consultation but that will be all that is needed.

This proposal looks set to be carried through but, given that a number of requests to the Secretary of State have been rejected in the past it seems unwise to remove this check. One suspects that the position will be filled by the judicial review process if local authorities do not carry out the consultations to a suitable standard.

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Tenancy deposit – late compliance again

Published
by
NL
on 07/11/2009
in Assured Shorthold tenancy, FLW case note and Housing law - All
. 20 Comments

Da Costa v Pinter Bromley County Court April 2008

With thanks to the November Legal Action housing updates. This was a tenancy deposit and 3 x deposit penalty claim. The rent was £1,950 a month. The tenancy agreement also stated ‘Payment required in advance of £4,200′. The invoice from the landlords agents said that of this, £2,250 was ‘a deposit’.

At the end of the tenancy, the deposit was requested by the tenant, but not returned. There was also no trace that the deposit had been protected in one of the schemes. The tenant brought a claim for deposit and the penalty. After the issue of proceedings, but before the hearing, the deposit was put into one of the schemes and details provided to the tenant.

DJ Burn ordered return of the deposit and the 3 x penalty. The DJ stated:

The purpose of the Act is to try to ensure that landlords secure tenancy deposits in a recognised deposit scheme at the start of the tenancy, so that the deposit can be returned to tenants quickly when the tenancy ends, and that disputes about the deposit can be resolved under the schemes’ procedures without the need for court proceedings.

Landlords who describe a deposit as something else, who do not secure it promptly in a deposit scheme as required by the Act, then fail to return the deposit when the tenant leaves (especially if this is without good cause, thereby forcing the tenant to start court proceedings to recover the money) but who then at the last minute after the tenant issues proceedings, pay the deposit into a scheme, are clearly flouting the spirit of the legislation and, on my interpretation, the letter also.

If the s213 and s214 remedies are not applied in a case such as the instant one, the Act would be rendered virtually toothless when landlords flout its provisions.

We are, of course, still in the land of the County Court lottery on the late compliance issue. None of these cases are binding on other courts. Harvey v Bamforth went one way and other cases, including this one, have gone the other. There does seem to be a distinct view on the spirit and purpose of the legislation emerging, through which the, to put it charitably, ambiguities of the Housing Act 2004 are viewed. But until we have a higher court judgment on the issue, there is no certainty.

[For all tenancy deposit case posts click here]

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Two homes, two MPs and an EDMO

Published
by
NL
on 24/06/2009
in Housing law - All and Possession
. 0 Comments

EDMOs, a remarkable power given to local authorities under Housing Act 2004 to take control of an abandoned or unused residential property and let it (and charge the owner for most of the related costs of doing so), have been used remarkably rarely – I am informed some 29 decisions on orders have been made in the RPT in England since the Act came into force.

Which raises a question or two over the threatened thirtieth order. Married Labour MPs Alan and Anne Keen, who were exposed in the Telegraph expenses porn spreads as both claiming for their joint second home – a flat in Waterloo – to the tune of £30,000 a year for the last four years, are facing a threatened EDMO on their property in Brentford. The Conservative controlled council are threatening an order on the basis that the property has remained unoccupied for 7 months. A Liberal Democrat councillor (and prospective Lib Dem candidate for MP for one of the Keen’s constituencies. I’m not saying which), Andrew Dakers observed:

that the windows at the back of the Keens’s main home were boarded up and that there was paint splashed on the inside of the upstairs windows.

which brings up worrying images of someone’s Lib Dem Counciillor hanging around the back alley (do they have back alleys in Hounslow?) peering in through the windows. People get arrested for less.

Between starting this post and writing this bit, the Keens have responded that the property was not unoccupied, just being renovated (those paint marks and all) – the BBC story has been updated – but apparently will still need to make a formal response to Hounslow Council.

Is it just me, or does this story make all concerned look more than somewhat ridiculous? EDMOs are not used, despite their real potential utility. How many EDMOs has Hounslow sought before this, one wonders – and as far as my cursory searching told me, the answer was none, but I have been corrected – there were two in 2008.

Given that the property has only been allegedly unoccupied for seven months, was apparently known to be the MP’s, and has councillors personally commenting on the state of its rear windows, that it seem be cynical publicity seeking on the part of the Tory Council and on the part of Mr ‘hiding in the shrubbery’ Dakers, the prospective Lib Dem MP, while the Keens are hardly covered in expenses glory on their two homes arrangements. Lovely.

For any Local Authority people reading this, we are genuinely curious as to why EDMOs aren’t used more often. Why not? Do let us know in the comments or in private email.

Update: The property has been squatted by a group apparently intending to make it a ‘refugee centre’. (Thanks Jim). I think this ends the EDMO, as the property has to be unoccupied – lawfully or otherwise – for it to go ahead. But I guess the Keens have other more pressing problems…

433276Photo from Indymedia.

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Tenancy Deposit – it gets worse

Published
by
NL
on 29/04/2009
in Assured Shorthold tenancy and Housing law - All
. 0 Comments

Hat tip to Tessa at Landlord Law for this. There are reports on various tenant/landlord forums of tenants losing Housing Act 2004 claims for 3x deposit on unprotected deposit/lack of notification cases where the landlord has returned the deposit to the tenant prior to hearing. Here’s an example.

This approach relies on the wording of s.214, specifically:

(2) Subsections (3) and (4) apply if on such an application the court—
(a) is satisfied that those requirements have not, or section 213(6)(a) has not, been complied with in relation to the deposit, or
(b) is not satisfied that the deposit is being held in accordance with an authorised scheme,
as the case may be.

(3) The court must, as it thinks fit, either—
(a) order the person who appears to the court to be holding the deposit to repay it to the applicant, or
(b) order that person to pay the deposit into the designated account held by the scheme administrator under an authorised custodial scheme,
within the period of 14 days beginning with the date of the making of the order.
(4) The court must also order the landlord to pay to the applicant a sum of money equal to three times the amount of the deposit within the period of 14 days beginning with the date of the making of the order.

[My emphasis]
The issue is the ‘must also’ at (4). The argument runs that if the court cannot order either (3)(a) or (3)(b), because the deposit has already been returned to the tenant, that ‘also’ means that (4) cannot follow or be ordered separately.

That is quite a nifty argument, at least on the strict construction of the Act, although it runs against the purpose. It has clearly had some successes, again all at County Court level, so no binding precedent. And it leaves the landlord able to avoid penalty by returning the deposit at any point up to the door of court.

But – in strictly thinking aloud terms – I’m not so sure it is so clear cut, at least assuming that the tenancy is still in existence.

What if the tenancy agreement specifies a deposit? Or even where, if the deposit was taken as a condition for granting the tenancy agreement, there is arguably an implied term that there is to be a deposit? The tenant would be in a position to argue that the return of the deposit is not the correct result and that the deposit – which is a contractual requirement of the tenancy – should be protected. It would be open to the tenant to refuse the ‘return’ of the deposit as a breach of contract. After all, a deposit is arguably in the tenant’s interests as well as the landlord’s.

On this line of thought, the tenant should tactically claim for an order that the deposit be protected, not return of the deposit, and claim for the 3x penalty, and then refuse any ‘offers’ by the landlord to return the deposit.

If the landlord then does protect the deposit, the case faces the lottery by District/Circuit Judge of whether late compliance avoids the penalty. Some say it does, some say it doesn’t.

Or are these just the fevered imaginings of a broken mind? It has been a trying couple of days.

For a piece of statute supposedly aimed at lay people, these parts of the HA 2004 must now be in the running for the worst drafted in recent times. We need appeals on all these issues, and soon. High Court or preferably Court of Appeal.

[For all tenancy deposit case posts click here]

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Tenancy Deposit on 'Renewal of Tenancy'

Published
by
NL
on 23/04/2009
in Assured Shorthold tenancy, FLW case note and Housing law - All
. 0 Comments

Our grateful thanks to the Painsmith blog again for news of another Tenancy Deposit case (and for giving me something to write about in these case bereft times).

This is a County Court case on the issue of ‘renewal’ of a tenancy that started before April 2007 and the introduction of the tenancy deposit rules. Where a deposit was taken for a tenancy prior to April 2007 there is no requirement for it to be protected. But when the tenancy is subsequently ‘renewed’ – actually a new assured shorthold tenancy – but the deposit ‘held over’ from the previous tenancy, does the deposit need to be protected?

This has been the topic of some argument, focusing on the definition of ‘receives a deposit’ in s.213 Housing Act 2004. My view has always been that this did not mean solely the physical transfer of cash or cheque and that the parties’ agreement that the deposit should be transfered to the new tenancy constituted the landlord ‘receiving’ the deposit.

I’m glad to see that HHJ Cryan at Clerkenwell & Shoreditch County Court agrees. This is not, of course, a binding judgment and other County Courts may well find otherwise, but I presume that the Clerkenwell District Judges will follow the Circuit Judge on this one.

I’m aware that Francis Davey, an NL contributor takes another view. Over to you, Francis?

As Painsmith’s blog rightly observes, this leaves the issue of when a fixed term assured shorthold lapses into a periodic tenancy under s.5 HA 1988 without a new AST being agreed. The weight of opinon seems to be that this is a continuation of the AST, but s.5 states that the periodic tenancy arises at the expiry of the fixed term tenancy. Arguably a new (periodic) tenancy and thus requiring deposit protection? No-one has run this yet…

[For all tenancy deposit case posts click here]

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Letting agents hit by TDS?

Published
by
Francis Davey
on 19/03/2009
in Assured Shorthold tenancy and Housing law - All
. 26 Comments

A recent blog post on the PainSmith blog illustrates a potentially nasty trap for letting agents (and useful alternative target for tenants) in the tenancy deposit protection system of the Housing Act 2004.

According to PainSmith a let-only agent received a deposit from the tenant and passed it on to the landlord who failed to register the deposit within the 14 day deadline.

The tenant has now brought proceedings for 3 times the deposit against the agent as well as the landlord, arguing that s.212(9)(a) of the Housing Act 2004 defines “landlord” to include persons acting on a landlord’s behalf and therefore the penalties in s.214 of the act apply to the letting agent as well as to the landlord.

I have always thought this argument must be right. Indeed it goes a little further than that.

S.213(1) requires that when a deposit is paid to “a person”, it must, from the time that it is received be dealt with in accordance with an authorised scheme. The “person” could be anyone (as in “leave it with the lady next door dearie”) and the date of receipt starts the 14 days ticking.

2.212(9)(a) is quite clear. It states:

references to a landlord or landlords in relation to any shorthold tenancy or tenancies include references to a person or persons acting on his or their behalf in relation to the tenancy or tenancies

This would appear to mean that the duty to give information to the tenant (and any “relevant person” such as a relative paying the deposit on behalf of the tenant) under s.213(5) also falls on the letting agent. As well as implying (as the tenant in the case reported by PainSmith contends) that a letting agent can be ordered to pay three times the deposit as a penalty under s.214(4).

That view is buttressed by the fact that s.214(3) permits the court to order the “person who appears to the court to be holding the deposit” to repay it to the tenant – that person need not be the respondent to the application nor a landlord or letting agent. The scheme is clearly intended to permit the courts to do actual rather than merely formal justice.

Finally if I am right then the likelihood is that letting agents will insist that they take charge of ensuring that any deposits paid to them are held in accordance with one of the approved schemes. That can only be a good thing. It is hard to see why a landlord would have a legitimate reason for wanting to prevent an agent from doing so.

Thus, the long run effect might be to put letting agents in a stronger position when dealing with landlords, to the benefit of tenants and letting agents both. Of course in the short run this is not good news for any letting agents who have left responsibility for the deposit with the landlord and legal uncertainty is a bad thing.

For tenants, the lesson is that if you paid your deposit to a letting agent you may have another target for complaint if the deposit is not properly protected.

[For all tenancy deposit case posts click here]

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Deposits – the mandatory award again

Published
by
NL
on 11/01/2009
in Assured Shorthold tenancy, FLW case note and Housing law - All
. 4 Comments

As noted by Tessa at Landlord Law, the current (January 09) Legal Action housing updates includes a tenancy deposit case which further muddies the waters.

Ferguson v Jones, Birmingham County Court 5 Nov 2008 concerned an assured shorthold tenancy. Ms Jones had paid a deposit of £500, which was not put into a scheme within the initial 14 days. In fact it was not put into a scheme by the landlord until after the landlord had brought a possession claim (presumably not on a s.21 notice) and Ms Jones had counterclaimed for disrepair and for the three time the value of the deposit under s214(2) and (3) HA 2004.

DJ Sheldrake held that the court had no discretion under s.214(4) and had to order the payment. The provision requiring the deposit to be protected within 14 days of receipt would be otiose if the landlord could escape the penalty by later compliance. That they should not was clearly parliament’s intention.

This is a County Court judgment, as have been all the reported cases so far, so there is no binding precedent on the matter. This judgment does run against the tide of the recent decisions, particularly Harvey v Bamforth, but it does make clear that, rather disappointingly for all concerned, whether late compliance will cause a claim to fail is a complete lottery at present (except presumably in Sheffield, where I would imagine HHJ Bullimore’s view is followed by the District Judges).

Anyone advising on a claim will just have to advise on the risk that late compliance may, or may not, defeat the claim. Tenants acting in person – surely the large majority in such cases, or indeed landlords, are not going to have any certainty at all. Someone take this to a higher court, please.

[For all tenancy deposit case posts click here]

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Deposits – another County Court decison

Published
by
NL
on 30/10/2008
in Assured Shorthold tenancy and Housing law - All
. 3 Comments

Tessa Shepperson at Landlord Law has a report from a landlord’s solicitor on another tenancy deposit case in the County Court, this time Bedford County Court.

In short, the Court found that payment of the deposit and provision of the required information by the landlord prior to the issue of a claim (and, County Court obiter, prior to hearing of the claim) meant that a claim for 3x the deposit failed. This claim was struck out under CPR 24. Note that this was after the landlord had failed to put the deposit into a scheme for over 13 months.

A practically interesting side point is that, because the tenancy had become a statutory periodic before the landlord protected the deposit, the private insurance deposit schemes (TDS and MyDeposits) wouldn’t take the deposit, so only the statutory scheme (DPS) was available. Odd. I have heard the contrary.

[For all tenancy deposit case posts click here]

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Harvey v Bamforth – now with the benefit of a transcript

Published
by
J
on 20/09/2008
in Assured Shorthold tenancy, FLW case note and Housing law - All
. 23 Comments

Harvey v Bamforth 8PA13344, HHJ Bullimore, Sheffield County Court, 8 Aug 2008

When we first commented on this case (here) we provoked quite a response. Thanks to to Mr Jones of Bury Walkers (who acted for Ms Harvey) we have now been provied with a transcript of the judgment. So – here is what it says.

Mr Bamforth was the assured shorthold tenant of a property owned by Ms Harvey. A deposit was paid to Ms Harvey via her letting agents. The deposit was lodged with TDS within 14 days of the start of the tenancy.

Rent arrears began to accumulate and, in January 2008 (the transcript says 2007, but I think that must be a typo) possession proceedings were issued. The proceedings were defended on the basis that the prescribed information (s.213(5) and (6), Housing Act 2004) had not been provided. It was accepted by the landlord that the prescribed information had not been provided within the time specified in s.213(5) and (6), but was said that it had been provided at a later date. However, it seems that the landlord withdrew the possession claim, leaving only a money claim for rent arrears.

Mr Bamforth then issued an application for the return of his deposit and for damages of three times the value of the deposit. His application was heard by a Deputy District Judge who ordered that the deposit to be returned pursuant to s.214(3)(b) HA 2004 and ordered damages of three times the value of the deposit pursuant to s.214(4) HA 2004. Both sums set off against agreed rent arrears. The DDJ granted permission to appeal.

Ms Harvey therefore appealed both the order for the return of the deposit and the damages award.

s.213 Housing Act 2004 provides (insofar as is material):

213 Requirements relating to tenancy deposits

(1) Any tenancy deposit paid to a person in connection with a shorthold tenancy must, as from the time when it is received, be dealt with in accordance with an authorised scheme.

(2) No person may require the payment of a tenancy deposit in connection with a shorthold tenancy which is not to be subject to the requirement in subsection (1).

(3) Where a landlord receives a tenancy deposit in connection with a shorthold tenancy, the initial requirements of an authorised scheme must be complied with by the landlord in relation to the deposit within the period of 14 days beginning with the date on which it is received.

(4) For the purposes of this section “the initial requirements” of an authorised scheme are such requirements imposed by the scheme as fall to be complied with by a landlord on receiving such a tenancy deposit.

(5) A landlord who has received such a tenancy deposit must give the tenant and any relevant person such information relating to—

(a) the authorised scheme applying to the deposit,

(b) compliance by the landlord with the initial requirements of the scheme in relation to the deposit, and

(c) the operation of provisions of this Chapter in relation to the deposit,

as may be prescribed.

(6) The information required by subsection (5) must be given to the tenant and any relevant person—

(a) in the prescribed form or in a form substantially to the same effect, and

(b) within the period of 14 days beginning with the date on which the deposit is received by the landlord.

…

Section 214 Housing Act 2004 provides (again, so far as it material):

214 Proceedings relating to tenancy deposits

(1) Where a tenancy deposit has been paid in connection with a shorthold tenancy, the tenant or any relevant person (as defined by section 213(10)) may make an application to a county court on the grounds—

(a) that the initial requirements of an authorised scheme (see section 213(4)) have not, or section 213(6)(a) has not, been complied with in relation to the deposit; or

(b) that he has been notified by the landlord that a particular authorised scheme applies to the deposit but has been unable to obtain confirmation from the scheme administrator that the deposit is being held in accordance with the scheme.

(2) Subsections (3) and (4) apply if on such an application the court—

(a) is satisfied that those requirements have not, or section 213(6)(a) has not, been complied with in relation to the deposit, or

(b) is not satisfied that the deposit is being held in accordance with an authorised scheme,

as the case may be.

(3) The court must, as it thinks fit, either—

(a) order the person who appears to the court to be holding the deposit to repay it to the applicant, or

(b) order that person to pay the deposit into the designated account held by the scheme administrator under an authorised custodial scheme,

within the period of 14 days beginning with the date of the making of the order.

(4) The court must also order the landlord to pay to the applicant a sum of money equal to three times the amount of the deposit within the period of 14 days beginning with the date of the making of the order.

…

Ms Harvey contended that the power to order the return of a deposit and damaged pursuant to s.214(3) and (4) only arose if the court was satisfied that s.213(6)(a) had not been satisfied and that compliance with s.213(6)(b) was irrelevant for these purposes. So – the power to order the return of the deposit and damages only arises if the landlord has failed to provide the prescribed information in the prescribed form (or one in similar effect). It is irrelevant, for the purposes of s.214(3) and (4) when that information is provided.

HHJ Bullimore accepted this argument. In his judgment:

[t]he failure on the landlord’s part was not that ‘the prescribed information was not given’ but that it was not given within the fourteen days. The district judge… took the view that [s.213(6)(a) and s.213(6)(b)] were so closely connected that they only made sense if they were read together but I think that was an error. I think that the draftsman in dealing with proceedings relating to tenancy deposits in Section 214 was very clear in differentiating between the requirements of giving information and giving the information after a specified period.

There were, to his mind, sound policy arguments for this conclusion:

… they are very serious powers to be exercised against a landlord… one can well see that in the minds of the legislators, it was one thing to deal with a landlord who had not provided the prescribed information at all and to deal with it in that way with a landlord who had provided the prescribed information but had not done it within that short period laid down by the Act.

Accordingly, as the information had been given before the tenant made his application, the application should have failed. The appeal was allowed and the order for the return of the deposit and the damages was overturned.

A final word of caution. This was only a decision of a county court and one that was only argued on one side (Mr Bamforth didn’t appear at the appeal). It is not a binding decision and other judges are perfectly free to come to other conclusions. As to whether or not it is right – I’ll leave that to you all to comment on!

[For all tenancy deposit case posts click here]

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