Unregistered agreements to extend lease terms may create equitable leasehold interests that must be taken into account in assessing compulsory acquisition compensation for lessees, and the choice of valuation methodology (DCF vs profit rent) for leasehold interests remains a question of fact for the trial judge, though the minority view suggests limits on using business earnings to value a leasehold interest.
The full text is available to signed-in members, including the 9 later cases that cite this judgment.