Bruton v London & Quadrant Housing Trust [1993]

House of Lords held that existence of tenancy did not
depend on grantor establishing proprietary interest.
Fact that grantor has no estate in land does not
preclude him from granting a lease.
Even if grantor is himself a mere licensee, if he
enters into contract which gives grantee right to exclusive possession for a
term, there will be a lease.
[ie Right to exclusive possession, the hallmark of a
lease, is now regarded not as consequence of ownership of the legal estate but
product of agreement between the parties.]