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[2000] QB 133 (CA). It has generally been assumed that to maintain an action in trespass to land, the claimant must have some proprietary interest in the land in question (that is, an Estate in land). More recently, it has been recognized that a person in possession of the land, without necessarily having a tenancy, might have standing (see: Delaney v tpsmith ltd (1946)). However, in this case the claimant airport had neither possession nor a proprietary interest. The airport sought to dispossess a group of environmental activists that had taken possession of a patch of woodland that needed to be cleared to make way for a new runway. The claimants had the permission (e.g., a licence) from the National Trust to enter the wood, the defendants did not. The court held (by a majority) that the airport could maintain an action in trespass, despite there being no clear prior authority for such a proposition. Since the claimant had a right recognized in law to enter the land for a particular purpose, although it was not in actual possession the activists were trespassers, as against that right. This decision has been widely criticised; although there clearly are circumstances in which it is desirable that a licencee be able to sue a trespasser, Dutton does not appear to be in harmony with existing authority.