As is well known the Protection from Harassment Act 1997 (hereafter the ‘1997 Act’) was a response to physical stalking after it had been held in Khorasandjian v. Bush [1993] QB 727 that the tort of private nuisance could not provide compensation to a victim who had no interest in premises associated with harassment suffered by stalking. The case which will be discussed in this note shows the extent to which developments, both by amendment of the 1997 Act, and by interpretation in litigation have expanded the circumstances in which compensation may be obtained.
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