Monthly Archives: November 2013

Easements and profits a prendre.


this is about the rights that someone may exercise over the land vf another

these are proprietary rights      they can exist at law and in equity

it is important fr the purchaser of land to know if a third party can exercise these rights over land

the law has strict rules on easements and profits

there are rules about how these rights can be created and acquired

easements rights of way, rights ti light,    right to water

these are more important than

profits a prendre – – right to enter another’s  land and to remove soil or produce of the soil


Names and characteristics of an easement.

two neighbours  come to an agreement that   since house A has  no garden   it owner can use the garden of house B.        if the right to use the garden satisfies the test of re ellenborough park  and it is created be a specified emthd it is an easement



DEFINitions doe not cover negative ewasements

———- dominant tenement. a piece of land which ebenfit from a rigt tp do somethin on or over neighbouring land

______________ servient tenement.    a piece of land over which another neighbouring land owner has rigjts.

—————————  proft a prendre.   aright to take something from alnad belonging   to another person for example a right t take fish from a land on land belonging to another

—————— legal easement.         an easement which was reated in  manner recognise at law and which complied   with the definitionn of a legal estate. . ie is equivalent to eiother a feree   simple abslute in possession or a term   of eyars absolute.

————————- equitable easement – any other vlaid easement   including  all those created  informally. this includes   any easement  held for a period   other than eitgher   a feee   simpele absolute   in possession or a term fo eyars

an easement  confers a benefiot on a piece of land  and a correspdongin  detriment on another piece of land

benefit and the budern    apply to the land itself and are not persoanl to the people who created it

an easament is a properiety intteers in the land and can pass with the kand to new owners subject to covneyancing       and registeration    requirements

this means that orucvhaser of the labd    ay find thet atbety are  ound by sucg pore esiting third party rights

tghere isa  dififyucle trbaslance if rightsibnvolved in the recvognition of easment s     becausr thye are propeity arriufhts   capable of passing wioth the land whcigh tehy affect and dfusour tghe sevient  landoqwners   use and enojoyment of his ladn

the law is creaful   not to epxnad      the catergort   of easement s too reaidly

the      defintion   of easments   mst not ebcime   too vague     or uncetai

but on the other hand easement may be necessary   for the sue and enjoyment  of domina t land ro may be commercially   valuable   and so the law must develop   with the passing of time therefore the category  of easement must not be closed.

it is difficult    to define an easement    in a really helpful  way due to the wide ranging  and  flexible nature     of the category     and it is the fore mor usual to explain   the nature of    an easement by reference        to its essential   characteristics   and by comparison  with other similar rights

the essential characteristic s   were ste out  by the court of appeal in

RE ellenbough  park

in that case      people who owned      house a round a parl wrre ganated    the right to use it as a lesure garden   but during the eat i twas taken over     by the government.      if the house woners had been deprioved        of a legal right     then they were entiteld to cpmetation under statute.   the only possible legal right     was an easewment on the facts. eventaully         the house owners succeeded               in convincing the court      of appeal that the right to use the park was an esament      \four factors were held to      be relevant in determing whether an easament exists

the ellenborough criteria       curreny mtaintint eh balance    of roghts mentioned above and are genertally paplied    but they are fleixble    and must not b treat as of they were statutory law

most texbooks contian        lists of examples f oghts which have been held to be easements



1…………… there must be a dominant and a serivent tenement

unlike a  proft    which may exist in gorss  ie. detached from eh ownership of the land –   an es,ane cannot exist indepently of     the ownership of the land     . an easement must      be attached  appurtenant      to a dominant tenement and it pasased ion a Y TRANDSFER       OF THE LAND   F0R ANJ INTERS          APPLICATIOON   OF THIS Principle, SEE LONDON AND BELMEHAIM ESTATRE LTD        V LADBROKE REtail park ltd

the above cases  hold that the creation of easements for land  not yet identified is not possible – they cannot exist independent of the land/



the right granted   must not simply        confer a personal advantage    unconnected    with the land – it must increasew     the nroaml enjoyment        of trhe land – see hill v     tupper

thus thr eight   to ut pleasure     boats on a canl for profit was not an easemrnt isnce it was held to be a personal advantage



a person      cannot have an easment over his own land

not that the concept of a quasi easement           under the rule in wheeeldon v burrows



since an easemrny must irginaste      in a gran whether epxres or implied    pr presumed   certain condtions must be fulfilled

a……………. there must be oth a capable granto and a capable grantee

b………………… the right must be sufficiently      definte.     if te nature        and extent of th claimed riught are uncetrain it is fifcult to dertmine what could cosnisute   an interruption of such a rigt

. cases involving                  claims to cfree access    of air il;lsutrate this point

‘ bryant v               lefevetr


the rights must be withing the gebnral  aure f rigths capable of existng  as easement

although  it is often said that the list of easements   is ot closed

it seems  that while the category    iof [positive easements   is likely  expand  with changing  social and economic  conditions

the courts will be reluctant to revongise   ay enw negative easements

positive easements   are those which allow the dominant         ownee to do something in servient land    – negative easements   are tbosew which prevent change in the servient land

phipps v pears   where rhr right claimed t protection from htrw ether wa probably too indefinite to be an esaet anweya

phipps –  it appares  unlikely       that a court will recognise   new easement which    require the seriven ronwe   to spend money

it is also   unlikely hat ane asmetn  Wil ne allowed if it give the owner the domaint t tement ar right ot prevent the owner oft a servient tenement from doing something       on this own labndparly becuasrthis id the more property viewed a s s trictive covenant

in addition     to the rule that easements       must generally      not  involve the sertvient    owner    in expenditure      neither can an intermittent    consensual privilege   or  a claim   to exclusive       or joint possession  of the servient       tenement   exist as easements

one difficulty is that courts     have had in drawing he distinction    between easements    , privileges    and exclusive       possession can be seen in relation    to the sokle issue of parking cards

there have been many cases in recent years concering parking rights    or at least permission to park on the laND OF AOTHER

NOTE THAT THRE IS NIO SPECIAL INMPORTANCR TIO THE parking cases – we are simply looking    t the as a common modern illustration of problems      involved in the recognition       of easmenets      but the right to  park      has ucvase problems    since in some cases  it has been considered too extensibve   and to mcuh interference  with the servient owners   use of his own land



A dream of sectarianism and funeral.


I dreamt of Northern Ireland. Could a Catholic be a loyalist or only a unionist? This is a question I have often asked myself? I had been considering this last night. It was difficult to be one. I heard Paisley’s irate voice booming out the need to be ”loyal Protestants” as a I walked down a road. To my right was a stone wall by a steep earth bank – there were oaks on the bank. The weather was unremarkable.

Later I walked into the gate of a churchyard. People in their 30s stood there dressed mostly in black. A funeral was about to commence. I did not know who the deceased was. Some of the mourners were smoking. I recognised Richard Coates among them and Emily the crazy one – both having a fag. The church was small and pale grey. It was not handsome and may well have been a Catholic church as such churches in Ireland are usually not impressive.

I had been walking around Eton at some point in my dreamt – in the cloisters.

Proprietary estoppel continued


it is uncertain    whether a  contracual licensee     could additonally rely    on restoplle

thimpson 1983 thinks so     but brigss   1981 does not

recent cases have changed     or developed a  number of ossies in relation   to interesrs   created by estoppel

you should    make notes on the relevant         facts, decisoons     and reasoning on each of the cases     and note what was gfiven to the successful claimants    in order to give effect to equitry

sledmore v  dalby      1996    the court odf eappeal     held that    though an eqauity       had arisen in favour     of the respondent it was not ;onger ine quaitable to deafeat it due    to the ebnefirst  wjch  eh had enhouyed over the eyar AND THE PARTOES SOTUATIONS AT THE TIME OF THE ACTION

thus        though dalby      could have had an estppel inters   he was given nothing


gillett v holt         2000

the defendant   had promised   to leavethe bulk of his estate to mr gillet           and had made a will doing so

subsequentyhe changed  his  will exclduing mr gillet     whose claim in properotry estopple     succeeeded

the court of appeal rejected       the idea thatr there had to be ”diuble aqssurance”

a second promise     that the defendant     would in noncirysmatcnes    chabnge his wil\ it was ernough    that the defdedant     had behaved unconsciobaly       by withdraweing    his promise adfter the claimant   had to know knowledg relied   on it to his detriment


yaxley v gotts      1999         court of appeal    held that    even wen an agreement    relating    to lane was vpid    for want fmorality      the doctinre     of properiotraytr    estoppel    could still operate     to cpmped on of the parties   to give   effect      to a promise     made under the agreement

banner group v    luff agreements    2000


hunt      v soady     court of appeal 2007              where there  had been a  provisional            agreement    that one beneficial      tenant     in common    H    would    transfer    her beneficial interest       to the other S               proprietary  estoppel                could not operate        since a that agreement    had not been       acted on by the other party          either in good time     or ot his detriment     ; it was    not unconscionable      for H          to go back     on her  representation     , particularly     given the substantial     change   in circumstances    since the time       of the provisional agreement


holman   v howes    2007

a divorced      couple bought property       together      being optimistic     about reconciliation and occupation

they both    contributed to the purchase price             but the legal title      was put into      the sole name    of the ex husband

he then   left    the house    but the     ex-wife     continued    to live there

on application      for an order    to determine      their beneficial      shares        with the ex husband         also seeking    an order for sale   , the court       held that the assurances   had been made     that the ex-wife     could occupy      the property    for as long as she wanted

since there    was detrimental       reliance  y the    woman the requirements     of proprietary estoppel       were satisfied   and thus un order to satisfy      this equity   there should be no order   for sale without the woman’s consent


james      v thomas 2007

where there was insufficient evidence  of a common intention that j should       have a beneficial interest   in the property    and assurances made   by T to J     were vague as to the extent of any beneficial interest    which J   might expect neither        a constructive     trust interest   nor one via    proprietary   estoppel could arise

the parties had lived   together   for  15 years  in a property   held  in T s sole   name – J     had helped    T with hus business      and together    they had conducted      extensive    renovations  of the property  . the assurances   which were found    to be too vague    were that the renovations would be for the benefit of both parties    and that J would be provided   for on T ;s death


powell and benney  2007

the appellants    P       had looked     after B;s couins    H   and had improved       his properties        for their own   use    after H   became unable   to look after himself       properly      and gave them the keys          to the premises

H  had promised   the      properties          to P upon his death       but he died     intestate     due to his will being invalid

the court       held that there was not strong         enough casual    link between    the promise     and the work    carried out for   P to receive        the entire     properties   as satisfaction for the equity          while P     had incurred             some expense     in improving    the premises   they had not been required   to do so by H

thus the case was a non bargain    proprietary   estoppel claim   Jennings   v rice     applied

to transfer   the properties       to P   would be out of all proportion   to the detriment   P had suffered   and so the trial judges award   of GBP 20 000    was upheld


yeoman’s row management    lrd   v cobb   2008

the house of lord   has shownt hat the esceptions to the law of preoperty   miscellaneoyus  provions   1989

are narrower   than previously thiought

a property  developer   reached    an oral agreement in principle   with an owner to buy its property   and then spent considerable sums   in obtaining    planning permission

the owner     then refused   to   proceed      on the agreed   terms and enter   into a binding contract

the house of lords   re\versed the decision    of the court of appeal   and held that the developer    was not entitled    to a remedy    based on proprietary    estoppel or a constructive trust  byut only   to a quantum meruit    payment  for his services    in pursuing  and obtaining planning    permission

since neither party   had thought that the agreement   between them had been enforceable

Y could not be estopped from relying upon      section 2 to show    that the agreement      was unenforceable

the agreement between the parties was a gentleman’s agreement   was too uncertain  as too its terms to constitute   a contract

the lower courts   had pushed   properitry  estoppel too far


thorner   v majors   2009

rather taciturn    farmer,   called pter, died    intestate   after revoking   a prevoous   will which ahd elft   the resideu   of his estate to david the son of his cousin.

this would  have given   peter’s farm  to david   .   the wil had been revoked      apparently     because pter   had falle out with one of the legatees    to whom he had givena sum of money, and wished      to exclude him.

the only way   in which david    could now succeed      in establishing    title   to the farm    was claiming     proprietary estoppel   because  on intestacy    the farmw ould now go to pter’s close er   relatives

david assisted    peter on the farm   for almost a 30 year oeriod   woithout    being paid an income.     at no point did pter             state to david             tyhat eh would leave       any property to him        after hi death. instead    david    had tio make out his case   frm inferecnes    , this was a watershed moment  turning david’s  hope of ingerting    the   famr into epxcetion   , following       this there were a number        of other comments made by peter   which david alleged   would ony have been made to a perdson who was spected             t inherit the farm

ewith lloyd LJ    giving the leading judgement        the court of appeal   reversed   the decision   of the court        below on the basius   that fir estopopel        to succeed    in these cases     the representation        had to be clear     and unequivocal     and not drawn from   inferences

but the case   was then appealed to the house of lords  who resvered the court of appeal decison     findind tat it had been  wroing to overutn the first instabce    judge decison    the trial  judge was best     placed to assess all thr parties dealing    and all the videncve before    him

for proprietary         estoppel to succeed          ot os indeed tj case that an assurance       must be clear enough   and must relate    to identified property

both the deceased       and the claimant   understood    that the property was to be a farm in the sate as it existed at the deceased death             whatever that might be,. the precise scope  of    the       property did not need to be agree din advance .        the house of lords disntibgusiebnd      cobbe v yeoman;s row            ont he gound that in cobbe                  there had bere  no doubt as to the phsycla identity of the property           bnut there had been compete uncertainty as to the                nature of the benefit given         to cobbe

in cobbe the relationship      between teh aprties was a commercial one at arms  length                 where the parties shAS CHOSEN NOT TO ENTER INTO A CONtract AND knew THat Were not  LEGALLY BOUND T O  EACH OTHER/

YOU would be advised tor ead this case    as the jdyeg considered preperty estoppel in detail.


henry v henry                     2010

the privy council   an appeal   from st lucia   in proprietary estoppel   case.  T   bought    the land    from an elderyly   relative G     just befotre the latter’s death.    G promised     to leave the land   in her will      to C    who had    lived on it and cultivated it for eyars.     the trail jduge      hgad dismissed C’s      cliam     on the basis that her had not suffered detrriment       he had recieved          a benefit     from the land         for ovr 30 yars        and T weas registered  proprietor   who had been given        value for  thje and and so took free    of C s claim

the court of appeal   howver    did find    that C had suffered    detriment     and hence          had an equity    which bound        T as an overriding       interest,. st lucia has a similar         land registration sysrem to england and wales

on appeal T argued      that since her purchase     of the land had not been unconsciobna;e      she should not be bound by any equity     which had arisen    in favour of C

the privy     conuncil        held that the trial judfe       had misdirected      himsefl    as to detriment    by failing   to weight up C ‘s advantage     s and disadvantages   resulting   from the promise –  kennings     v rice  applied –

the court of appeal    had also been mistaken        in tis ppaorach     to detriment

hence the PC had to consdier      tyhy issue afrsh     and gound that c    HAD Deprived        himself    of better life   elsehwere       bey remaining     ont he lad

that detriment    had not been       outweighed    by the advantages    he took       from his hard life   in which he has had tos struggle to make ends meet occupying the land

the resulting      estoppel  equity       was satisfied       by awarding         C half    of T ;s share   of the plot if land

i e quarter of the total

proportionality      is at heart   of proprietary estoppel

the privy council       looked at the effect   of an estoppel         equity           on third parties

the privy council    looked at an effect    of an estoppel    equity     on third   parties    and noted    obiter    that there may   be cases   in which circumstances   of a third party   purchase   might requite    a claimant’s    equity   to be reassessed even thought     the claimant  has an overriding interest

——————— the land registration act 2020    provides   that an equity     by estoppel  ”has effect   from time the equity arises   as an interest  capable of binding   successors in title”

thus it is confirmed     that a uncystrallised   estoppel   ”equity”   can bind a transferee  if protected   as required   by normal  rules of registered   or unregistered   land

in registered land  it can be protected   by an entry    on the register    or coupled with actual   occupation  is capable    of overriding   a disposition

but once the court has granted    a remedy then whether    a transferee   i sbund   will depend   on the nature of the remedy

if a remedy is a freehold or an easement  then it will bind a trasnferee    but it it is a licence   or financial compensation   then it will not


A dream of boats and my family.


I was on a small white yacht. The weather was fairly good. There were a few other people aboard. We were on a lake in a European country. We slowly sailed into a marina. Scores of other similar craft were moored there. There was scarcely any room. I do not remember what the town was like. I got off the boat and walked along the wooden jetty. Somehow I knew that this was a place for people having a baby. This is bizarre since I saw no pregnant women. I saw no one on the jetty but this did not seem incongruous to me. There was so little room that the boats were all reorganised and packed in in a new formation. 


There was something about speaking to my second cousin once removed there – Kevin. I had tried to call him on skype. He had not answered last night. Kevin was not in this town.

Later I sailed across the long lake. There was verdure on either shore. We sailed into a small town with buildings fashioned of stone. It looked a little like Bonicifacio which I visited this summer. I got off the yacht I did not see anyone but this was not eerie. 

I sat on the clean and polished stone. It did not feel cold which one would have expected. I saw members of my family coming. i had not expexted to see them. My mother, my brother in law and my eldest niece. I tried to avert my face so they would not spot me. Then My brother in law caught sight of me. I came out and greeted them.

Later I was seated at a table with my family. There was a clash with my mother. She said something about why I should buy some espedrils because they are reasonably priced there.I was irritated at her telling me what to do all the time.

I thought about how I disliked the place in Ireland where they lived. There may have been other chapters to this dream.

What can it all signify – the boats, the family and the towns?

Proprietary estoppel.


much like the law relating to contracual   licences    the doctrine of proprietayr estoppel    has developed    on a striking manner    over the last 30 years

the sceope of the doctrine    has veen continuously      extended    by the sourts with little heed for the conveyancing   ptroblrms that may be caused

the boundary    between contractual licences    and estoppel    licnes may   smetime sbe diffciult    to draw but the diffetrence in results  may be striking

if the lement of request    or agreement  between the parties  is the distinctive  feature   of contractual licenses it is paradoxical   that the contractual  licensee  should be n a weaker position  – particularly  in relation to the third parties – than the estoppel  licensee.

the doctrine  is increasingly   used to give effect   to grants that fall foul   of the rules for the creation  of property   rights ass in cobbe  v yeoman’s row

it also provides   an increasingly   important exception to the principle  that equity  will not assist   a volunteer

in some cases  lim teng huan  v ang  swee chuan the doctrine  may fikll the riole of the old law if part performance



The classic statement   of the doctinre   awa made in lord kingsdown   dissenting speech in ramsden    v dyson

”  if a man   under a verbal agreement  with a landlord   for a certain interest   in land or what amounts   to the same thing under an expectation , created    or encouraged   by the landlord, that eh shall have a certain interest    take possession     of the land with the consent    of the landlord and ipin the faiht of such a promise or expectation    with the knowledge of the landlord and without objection  by him lays out      money upon the labnd     a xourt of equity   will compel     the labdlord    to give effect   to such  promise or expectation.”

kingsdown’s dictum   is frequently   quoted   with approval but the scope of the doctrine    has been considerably   extended   in recent times

where the owner     of land knowingly      encourages anither      to act or acquiesces         in his acting to his detriment       on the understading     that he is to have anj intyeres in tta land the owner will subsequently   be estopped froma sserting   his strict legal rights   – and may be   coimpelled ti give effect   to the equity   that has arisen   in favour of that other –

elements are

—————- a representatiion

——————— reliance/change of position

———————- detriment/ disadvantage    ie    an expenditure    or loss to the promisee

—————— unconscionability     i e   all the circumstances    it is unconsciobale   that the promisor   should be able   to rely upon   his strict legal  rights by breaking  his promise

Note –

the doctrine may still apply    where the ioner was ignorant of the true   legal psoton at the time he encouraged    the other person toa ct

the questions is simply whether it would be conscionable  to allow him ti insist  on his strict legal rights

taylor fashions   ltd v      liverpool   victoria trustees   co ltd

matahru    v matahru   1994           a claimant was successful    even thought eh owner  doe snot seem to have made any promise or representation       encouraging her to believe what she believed

————– though in many    earlier cases  the climant had spent   some money  on the labd it is sufficient  toay if he has suffered some detriment   as a resukt of his doing or omitting to do somethibng,.

no only do the courts   take a broad view  of what constitutes detriment   byt the CA has held     tyhat where   a repdsresantaitb  has been made   there is a rebuttable presumption    that the claimant     has acted  in reliance on it   . the onus is on the defendant to prove otherise

greasley v cooke

———– in most cases   the repsresnation has related to a parciula rproperty  in whcib the climant  has an existing intyerers. but the court in re basham     – where the cliamnt    lived in ehr own house at some distance  from the deceased   house – refused   to restrict   the operation of the doctrine     in this way

————— it was also held    in re basham   and again  in wayling  v jones    1993         that the doctrine   applied   to the situation where a person encourages    another to act to his detriment    on teh understanding  that he will inherit  certain   property  on that person’s death

——————– an important      change of [perspective   has occurred  in recent cases.  gillett  v holt    and  jennings     v rice      make it clear    that courts now applying a more holistic approach   to proprietary estoppel case nd judging fact  in the round    to determine whether   the claimant has an estoppel  equity   and how it should be satisfied     the need for the claimant      to prove unscioniobauility    has become a central factor in propoerty estoppel.



once an equity  has been estabished     how will the court give   effect  to it?   it is difficult   to find any consistent   princople  running throygh the cases

in instances of dodsworth  v doswoerth       and burrows and burrows v   sharep     – compensation     for expenditure       incurred   was considered   the appropriate    remedy  – particularly     as it would have been   impracticable   to have required    the parties   tpo contiunue  living  together –

it must be admitted   that this solution   does avoid    conv4ynacing [problems

crabb v    arun district c council rights of access   and way were awarded

in griffiths    v williams    non assignable   lease for life was awarded

the CA     int his case was aware          – as was ther CA ibn   dodsworth –     that trhe award    of a life interest    , such as had been made in inwards   v baker       and jones v jiones    would have the effect of creation   a settlement under the settled land act 1925

and would therefore   give the claimant   a greater interest    than was within    the parties   expectation it is clear from dent v dent    wherever that an exclusive    right to occupy     property   for life does not necessarily    constitute   a life interests   under a settlement

finally   there    have been case whwrr the courts    have held that the equity    has arisen inj the claimant’s favor   can only be satisfied    by the transfer   of a fee simple  to him

ungurian v   lesnoff    ,       vinelott  J   held that   as it was   the intention  of the parties    that the defendant   should have the right    to reside in the plaintiff’s    house for life , the house becane settkled land within the SLA    and the defendant   was the trnant fior life

since the coming into force     of the Tursts iof Lan and Trsutrees Act 1996, a life interers  of this kind would take affect   under a trust of land

as examination of cases shows   the ranger of remedies   warded by courts   to satisfy   and estoppel  equitry    is great rnagung  from cpneptnsaiton to licnes    to leases   to freehols

there do appear to be   two methods  by whcuh cpurts have calcuated           the appropriate   tmrfy; sometimes  acourts appear  to be giving     effedct           to the climaiunts  reasonable expectionat   and in other cases c oruts     appear to have complete discretion    as to the choice     or remedy it now appesrs   that courts  a re combining   both approaches   by considering  the cliamnts expcetation  andf then snuring that there is proportionality     ebtween the detriment    and the rmyd awrded

jennings  v rice     the court considered     botha pporaches         and hedl that it was not appropriate      to grant     a  remdy merely    on the basis     of the climaints   expectionstions        nor could the court have   absolsute discretion

according to lord justice  Walker ”it cannot be doubted   that n this as in very other area of law”              the court   must take  principled   approach cannot exercise a complete unfettered discretion  according  to the individual judges notion.of what is fair   ub NT PARTICYlar case.”

hence    although the interest   expected  by the claimant   was a  relevant    consideration., the court    must do justice   by ensuring     that there is proportionality   b between the remedy and the detriment   – once    estoppel     equity   has been generated

”teh value     of that equity   will depend upon all    the circumstances   including    the exceptions    and the detriment.   the   mos essential    requirement   is that there must be proportionality    between    the expectations and the detriment”

the modern approach   is to award the minimum equity     to do justice on the fats of the individual case.    this might be nothing as  in

sledmore     v dalby

or a combination rm edy   as     gillett v holt


The British Indian community


I have been watching a lot about the British Indian community. This community is growing in wealth is very self-assured. There have been Labour MPs of Indian origin since the 1980s. There are now several Conservative MPs of Indian origin.  (In fact there was a Liberal MP and a Conservative MP way back in the 1890s who were Indians but they were blips. Then there was  Communist MP who was a Swedish-Indian in the 1920s.) When a community produces Conservative MPs it means this community is accepted. The British Indian community is now well-established. It is only going to become more numerous. Not all British Indians are keen on immigration from Eastern Europe. 

I see programmes broadcast in India about the Indian community in the UK. A lot of it is positive stuff about temples being built and so on. They also show racist attacks. Sadly these disgraceful incidents occur but too much focus on them will give people in India an overly negative impression of the United Kingdom.