[2005] EWHC 856 (Ch), 16 May 2005. Considers whether the Limitation Act 1980 Sched 1 Part II para 12 provides a complete code for possession claims brought by persons claiming through the Crown. Claimants (C) claimed title to the disputed land by adverse possession. Up to its abolition in 1986 the Greater London Council (GLC) had been the registered proprietor of the land when it became Crown land. In 2000 the land was vested by the Crown in the defendant Transport for London (T). C contended that T had no right of action under para 12 because the right of action had not first accrued to the Crown but to the GLC. T submitted that para 12 was a complete answer to the claim since the word first in the phrase first accrued to the Crown, meant earlier or previously and not originally. "Held": judgment for the defendant. The word first in the phrase first accrued to the Crown meant earlier or previously. Para 12 provided a complete code of possession brought by persons claiming through the Crown. C's claim failed on the facts as they were not in adverse possession from before the key date in 1986.