Since the 13th century this has been complicated by flying freeholds, the right of aircraft to fly over a property (as in Bernstein of Leigh v Skyviews & General Ltd[1]), the Crown's claim on certain resources and mineral rights (as in the Case of Mines[2] Coal Industry Act 1994, Petroleum Act 1998) and treasure (Treasure Act 1996). Nevertheless, cases such as Kelsen v Imperial Tobacco Co Ltd[3] and Laiquat v Majid[4] illustrate that the courts generally support the freeholder's right to control things that overhang or underlie the ground he holds.