9Locality wouldn’t be a factor in deciding whether physical damage is unreasonable as this would be assumed , but A’s case involves use and enjoyment of his land, so it is. If it was purely a residential area the factory noise and vehicle activity late at night would be more likely to be a nuisance . But, ‘what would be a nuisance in Belgrave Square would not necessarily be a nuisance in and A moved to a house opposite a business, so some interference is to be expected, however, the nature of the locality can change over time, and the courts must consider it as it is, not how it once was Even if SS have planning permission to expand their business this wouldn’t stop it being a nuisance, but it is a factor that can be considered when awarding a remedy (Watson v Croft). In Gillingham the nature of the locality changed but in A’s case it hasn’t as it was already a business, but not one at night, so this is a factor in favour of it being unreasonable.