Bocardo v Star Energy and another

A freehold landowner is, prima facie, owner of and in possession of the strata beneath the surface to such depth as may be exploited, and can sue in trespass for unauthorised drilling beneath the land; the statutory licence to extract petroleum did not confer any defence to trespass, and compensation is to be assessed by analogy with the Mines (Working Facilities and Support) Act 1966 rather than on a 'ransom' basis.