[2006] EWCA Civ 815, 22 June 2006. Considers the rules of succession relating to the Housing Act 1985 s88. Appeal by W against a decision that he was not entitled to succeed to a secure tenancy on the death of his mother. B had let a property on a contractual joint tenancy basis to W's parents and on W's father's death W's mother became the sole contractual tenant by right of survivorship. Her tenancy became a secure tenancy under the Housing Act 1980 whose provisions became consolidated into the Housing Act 1985. B sought possession after the mother's death contending that W could not succeed to the secure tenancy because his mother had already been a successor within s88(1)(b) of the 1985 Act. "Held": appeal allowed. W's mother had become the sole tenant on her husband's death but was not a successor within s88 of the 1985 Act so as to prevent W from succeeding her under a secure tenancy. No provision of the relevant legislation treated retrospectively either the joint tenancy or the survivor's sole tenancy as a secure tenancy before the 1980 Act came into force.