Local government – Council tax. The appellant listing officer held that the annex at the respondents' property was a self-contained unit, amenable to a separate charge for council tax. The Valuation Tribunal for England (the tribunal) allowed the respondents' appeal. The appellant appealed on the ground that the tribunal had failed to apply the physical characteristics test. The Court of Appeal, Civil Division, in allowing the appeal, held that the tribunal's decision had not set out the correct test, nor had its terms, as a whole, suggested that the correct test had been applied sub silentio.