[2008] EWHC 1432 (Ch), 2 June 2008. A social landlord was not entitled to unilaterally vary the terms of its tenancy agreements under a clause that claimed to incorporate the mechanism under the Housing Act 1985 S103, that contradicted a preceding clause that provided for variation through agreement with the tenant. The court was asked to determine whether social landlord (P) could make use of a clause in its tenancy agreements to vary agreements unilaterally under the Housing Act 1985 S103 and if the clause could be considered as not-binding under the Unfair Terms in Consumer Contracts Regulations 1999. Held: judgement for defendant. While unilateral changes would have benefited P and prevented its stock from becoming unmanageable, it was a risk that the legislature allowed to exist, with the assumption that social landlords would be able to cope. In addition to this, it was held that the existing tenancy agreements made sufficient provision for future events and that P had no reason to require such a sweeping clause in relation to all of its agreements.