Relief from forfeiture and possessory rights

In Vauxhall Motors Ltd (formerly General Motors UK Ltd) v Manchester Ship Canal Co Ltd [2019] UKSC 46, [2019] 3 WLR 852, the Supreme Court held that the jurisdiction to grant relief from forfeiture of rights relating to land did extend to possessory rights and was not confined to proprietary rights in relation to land. The inclusion of possessory rights within the scope of the jurisdiction was held not to introduce an unacceptable degree of uncertainty into English law.