We have seen that market value may include any potential or development value. If land is being sold in the open market, purchasers will take into account the value of existing planning permission, or the possibility of obtaining planning permission if permission is not immediately forthcoming. The House of Lords in Spirerose Ltd v Transport for London [2009] critically examined both the statutory provisions relating to the assumption of planning permission, contained in sections 14 to 17 of the Land Compensation Act 1961, and also the application of the Pointe Gourde principle to the same problem. In consequence of this, and several other decisions of the Lands Tribunal and the Court of Appeal, section 232 of the Localism Act 2011 introduced significant changes to the statutory arrangements in the 1961 Act for the assumption of a planning permission in the assessment of the rule (2) open market value of land. The main amendments apply to any compulsory purchase order confirmed on or after 6 April 2012. The old provisions apply to compulsory purchase orders confirmed before that date. This chapter considers both the old and the new provisions.