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[1953] WLR 62 (CA). The claimant tenant obtained damages against his landlord, the defendant, for breach of contract. The landlord had compelled the tenant to leave by cutting off his electricity supply. The tenant was also awarded damages for trespass to land, it being maintained that cutting off the electricity was an interference with the property rights of the tenant. This latter awarded was set aside by the Court of Appeal, on the basis that a trespass requires some form of intereference with the land itself. Cutting off the electricity does not affect the land, only the tenant's use of it.