[2006] EWCA Civ 1387, 26 October 2006. The appellant secretary of state appealed against a decision that a planning document issued by a local authority was a certificate of lawful use of proposed development under the Town and Country Planning Act 1990 s.192 since it was "substantially to the like effect" as the form set out in the Town and Country Planning (General Development Procedure) Order 1995 Sch.4. Decades earlier, planning permission had been granted to the site for change of use to a garage and store. The respondent applied for a certificate of lawfulness for an existing use on the basis that the site had benefited from an extant grant of planning permission. The local authority issued a document stating that the original planning permission granted decades before was not personal to the previous occupier, and that the store and Class X use referred to therein was now covered by reference to storage in the Use Class B8. The respondent argued that that document was "substantially to the like effect" as a certificate of lawful use under s.192 of the 1990 Act. A planning inspector held that the document merely responded to specific questions and was not, therefore, an s.192 certificate. "Held": The document was not in the form prescribed by Sch.4 of the 1995 Order. The document did not on its face purport to certify that any and if so what use was lawful. It was not clear that the local authority had satisfied itself, as it had to be satisfied pursuant to s.192(2) of the Act.