## Facts

- Lord Eglinton, steward of the Doncaster races, authorized sale of grandstand admission tickets for one guinea.
- Wood bought a ticket understood to allow entry to the grandstand and surrounding enclosure and to remain there during the races.
- Due to alleged prior misconduct connected with the races, Lord Eglinton ordered Wood removed from the enclosure.
- Leadbitter, Lord Eglinton’s servant, instructed Wood to leave and warned that force would be used if he refused.
- Wood refused to depart; Leadbitter removed him by taking him by the arm and ejecting him, using no unnecessary violence.
- The guinea paid for the ticket was not returned.
- Wood sued Leadbitter in trespass for assault and false imprisonment.
- Leadbitter defended on the ground that he gently laid hands on Wood to remove him from Lord Eglinton’s land after Wood’s permission to remain had been withdrawn.
- The central dispute became whether Wood was still present by Lord Eglinton’s “leave and license” when he was removed.

## Issues

1. Whether a paid ticket conferring permission to enter and remain on land during an event creates an irrevocable right to stay for that period.
2. Whether a landowner may revoke such permission without refunding the price paid.
3. Whether, after revocation, notice, and reasonable time to leave, the landowner’s servant may lawfully eject the person using only necessary force.

## Decision

- The Court of Exchequer upheld the trial court’s direction and discharged the request for a new trial, leaving judgment for Leadbitter.
- The court held the ticket created, at most, a nondeed (“parol”) license, not an interest in land.
- The license was revocable at the landowner’s will, even though given for value and expressed for a fixed duration.
- After revocation, and after notice and reasonable time to depart, Wood became a trespasser and could be removed using no unnecessary violence.

## Legal Principles

- A bare license to enter or remain on another’s land grants no estate or interest in land and is revocable at any time by the licensor.
- A right to enter and remain on land for a definite period, as a property interest, must be created by deed; a nondeed license cannot operate as such a grant even if consideration is paid.
- Payment for entry may support a separate contract claim, but it does not prevent revocation of a license for purposes of trespass and possession.
- A license “coupled with a grant” may be irrevocable when entry is necessary to enjoy an accompanying proprietary grant; a mere right to be present at an event is not such a case.
- Upon revocation with notice and reasonable time to leave, a former licensee who remains is a trespasser and may be ejected with only necessary force.

## Conclusion

The court treated the race ticket as a revocable license rather than a property interest, holding that the landowner could withdraw permission without refunding the price and, after notice and reasonable time to depart, could lawfully have the ticket holder removed using no unnecessary force.


Wood v. Leadbitter, 153 Eng. Rep. 351 (Exch. 1845)