---
title: Walford v David
description: "Case Report: 1989 SLT 876 **The facts:** The Crown Estate had provided a grant to use the sea for a fish farm. It was alleged that floating fish farm cages interfered with the public’s navigation rights. **Decision:** The court said that the…"
url: "https://scotways.com/ken/walford-v-david/"
updated: "2025-06-05"
category: Navigation rights and rights in relation to the foreshore / Navigation rights
tags:
  - Access to Water
  - Case Law Navigation rights and rights in relation to the foreshore
  - Court Case
---

# Walford v David

Case Report: 1989 SLT 876

**The facts:** The Crown Estate had provided a grant to use the sea for a fish farm. It was alleged that floating fish farm cages interfered with the public’s navigation rights.

**Decision:** The court said that the Crown Estate was entitled to make a grant to allow fish farming provided that this activity did not amount to a material interference with the public’s right of navigation. The fact that the use is a nuisance or inconvenience is not enough to constitute a material interference. However, if the exercise of the private right makes the public right impossible, then the public right of navigation prevails.

**Comment:** In this case the fish farm cages could be avoided easily by exercising normal navigational care and they were therefore not a material interference.