We all know about the presumption in favour of development which is in conformity with the development plan which dates from the introduction of s.54A TCPA 1990 in 1991. But what about its simple predecessor? When was it first articulated? From memory we think it was referred to in DoE Circular 1/85 and also in the Dobry report of 1975. So it must be earlier than that. Was it part of the plan of the 1947 Town and Country Planning Act? We think that it was but are having trouble tracking down a source. Why is it relevant? We think it's important in the context of calls for third party rights of appeal.