[2005] EWCA Civ 284, 17 March 2005. Considers whether the notice to quit scheme under the Agricultural Holdings Act 1986 was incompatible with the Convention for the Protection of Human Rights and Fundamental Freedoms after the coming into force of the Human Rights Act 1998 because it discriminated contrary to Art 14 of the Convention between agricultural tenants facing eviction for failing to maintain holdings and tenants facing eviction for failing to improve them. Appeal by tenant (T) against respondent local authority's (L) order for possession of his agricultural holding ([2004]) EWHC 776 (QB), Abs67747). T had used his holding for business other than agricultural purposes. L served T with notice to quit under the 1986 Act Sched 3 Part I Case D. Statutory arbitration determined that the notice was valid and T's consequent challenge failed. T sought a declaration following s4(2) of the 1998 Act that the notice to quit provisions of the 1986 Act were incompatible with the Convention. "Held": appeal dismissed. T was not a victim for the purposes of s7 of the 1998 Act or the Convention. The differential treatment of tenants under the 1986 Act did not depend on their property or status within Art 14 of the Convention but solely on the content of the covenant alleged to have been breached.