The locality where the interference occurred also influences whether or not it was unreasonable; in Sturges v Bridgman,[1879] LR 11 Ch D 852 Thesiger LJ wrote that "what would be a nuisance in Belgrave Square [a residential area] would not necessarily be so in Bermondsey [a smelly industrial area]". If an activity is out of place with the locality, it is likely to be held as unreasonable. However, the nature of areas can change over time; in Gillingham Borough Council v Medway (Chatham) Dock Co Ltd,[1993] QB 343 it was held that the granting of planning permission to develop a commercial dock in an area changed that area's character, preventing the local residence from claiming in private nuisance for the disturbance the dock created.Bermingham (2008) p. 228 The granting of planning permission does not constitute immunity from a claim in nuisance, however; in Wheeler v Saunders Ltd. the Court of Appeal said that it would be "a misuse of language to describe what has happened in the present case as a change in the character of the neighbourhood. It is a change of use of a very small piece of land... it is not a strategic planning decision affected by considerations of public interest. Unless one is prepared to accept that any planning decision authorises any nuisance which must inevitably come from it, the argument that the nuisance was authorised by planning permission in this case must fail".Bermingham (2008) p. 229 In situations where the defendant's activities cause physical damage, as in St Helen's Smelting Co v Tipping, the locality of the activities is not a factor in deciding their unreasonableness.
