The case upheld the validity of a scheme of development. Parker J found 4 separate requirements for such a scheme:
- The claimant and defendant purchased land from a common vendor
- The common vendor set out plots of land in advance of sale, with common restrictions to be imposed
- The common restrictions were to be imposed and for the benefit of all lots intended to be sold or retained
- The claimant and defendant purchased their plots knowing that the common restrictions were to enure through their purchases – this final requirement may be inferred from the first 3
