When a tenant repeatedly refuses access for inspections or safety checks, an injunction for access can be a practical next step. Tenancy agreements typically include access clauses, and landlords carry statutory duties, for example, to maintain gas and electrical installations.

An access injunction, usually with a penal notice, can focus minds – but what if the door remains shut, even with an injunction granting access? Does the Court have jurisdiction to grant an injunction for access?

The question has been considered in a series of County Court cases in recent years, starting with Sovereign Housing Association Ltd v Hall in July 2024, followed by Southern Housing v Emmanuel in October 2025, Taylor Clark Ltd v Mohamed in March 2026, Plymouth Community Homes Ltd v Hammond in May 2026, and, most recently, Stonewater Ltd v Rosie Marie Harris, decided in Southampton County Court on 13 July 2026.

Four of these five decisions have supported the availability of forced access, although the courts have taken different approaches to the issue.

So, where does this leave landlords?

The latest decision in Stonewater confirms that County Court judges can, in principle, authorise forced access where a tenant has failed to comply with an access injunction. Crucially, however, there has not been any decision above County Court level; whilst the above decisions may be persuasive, they are not binding and each application for an injunction for access would fall to be determined on its own merits.

The court will also want to understand the circumstances of the tenant and anyone else living at the property, including any vulnerabilities. Any forced access should generally be preceded by at least reasonable notice.

Whilst this latest decision provides welcome practical guidance for landlords, the position remains subject to further development, as the issue has not yet been considered by a higher court.

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