‘Out of clutter, find simplicity’
(Wheeler Reference Wheeler1979)a
In 1947, Erich Fromm described a ‘hoarding orientation’ as a non-productive character type in which individuals find security in accumulating and retaining material goods (Fromm Reference Fromm1947). In 1963, Scandinavian psychiatrist Jens Jansen’s study of ‘collector’s mania’, describing older adults who excessively overfilled their living spaces with an abundance of objects (Jansen Reference Jansen1963), bridged the gap between Fromm’s early psychoanalytic concept and the empirical diagnostic criteria established in the late 1990s. The article by Iles et al (Reference Iles, Attard and Attard2026) in this journal brings readers into the 21st century with its exposition of Frost’s cognitive–behavioural model (Frost Reference Frost, Steketee and Tolin2011).
Beyond the numbers
Iles and colleagues set out the generally consistent findings on the epidemiology of hoarding disorder. Another useful study is a systematic review and meta-analysis by Postlethwaite et al (Reference Postlethwaite, Kellett and Mataix-Cols2019), which estimated the prevalence of hoarding disorder at 2.5% (95% CI 1.7–3.6%) in high-income countries, with similar rates in males and females; although, among children and adolescents, females outnumber males 3:1. This equates to between 1.2 and 2.5 million people in the UK and well over 1 million affected households, as older adults with hoarding disorder are more likely to live alone (Woody Reference Woody, Lenkic and Bratiotis2020).
As the authors demonstrate, this represents a considerable mental health burden because of hoarding disorder’s comorbidities: generalised anxiety disorder (at 24%), social anxiety disorder (23%), attention-deficit hyperactivity disorder (28%), obsessive–compulsive disorder (OCD) (18%) and depressive disorders (51%) (Frost Reference Frost, Steketee and Tolin2011; Novara Reference Novara, Bottesi and Dorz2016; Bratiotis Reference Bratiotis, Muroff and Lin2021). Although the authors refer to over 60% comorbidity with other mental disorders, this may be an underestimate, as many people with hoarding disorder have multiple disorders.
The authors highlight the association of hoarding with fire risk. In the 5 financial years 2020/2021 to 2024/2025, there were 1771 hoarding-related fires in England (Ministry of Housing, Communities and Local Government 2026). The risk includes fatalities. In a study of 48 hoarding fires in Melbourne’s Metropolitan Fire District (Australia), there were 10 fatalities, accounting for 24% of preventable residential fire deaths during the 10-year study period (Lucini Reference Lucini, Monk and Szlatenyi2009).
Hoarding frequently leads to squalor, eviction and extreme social isolation, creating a major burden on local authorities, housing associations and the National Health Service. Tackling the problem requires multi-agency safeguarding and cooperation between local authorities, health and social services, landlords, fire services and charities such as Hoarding UK, which provides telephone helplines, peer support, advocacy, guidance and mediation. Successful collaboration can resolve cases without court proceedings. Along with Everything You Need to Know about Hoarding (Drummond Reference Drummond and Edwards2025), the article by Isles et al will be an important resource for these organisations.
Unfortunately, some cases require legal proceedings, and their article will assist psychiatrists and psychologists providing expert evidence, the lawyers instructing them and the courts receiving that evidence. These are some key legal principles involved.
Hoarding and legal proceedings
The courts and tribunals where hoarding issues are resolved are mainly the Court of Protection, but also the County Court and the First-tier Tribunal (Property Chamber). Court of Protection cases arise where public authorities seek to intervene but capacity is in issue. County Court cases usually concern possession proceedings based on tenancy breaches arising from fire hazards, vermin, rotting rubbish or inability to carry out safety inspections. The First-tier Tribunal cases often concern property condition and repair disputes.
The following cases, including the seminal Court of Protection case AC and GC [2022], which Iles et al consider, are ones to which psychiatric and psychological experts can usefully have regard.
Case 1: The right to personal autonomy
P v M (Vulnerable Adult) [2011] concerned an 82-year-old woman with dementia and hoarding tendencies who was placed in a care home. She wished to return home, but her house was highly dilapidated, dangerous and cluttered. The case highlighted the tension between personal autonomy and the duty of public authorities to protect those at risk from severe self-neglect. The court held that adults have the right to live with a degree of risk, balancing her long-standing attachment to her belongings against the imminent health and safety hazards.
Case 2: Capacity
In AC and GC (Capacity: Hoarding: Best Interests) [2022] a local authority sought to move a 92-year-old woman with dementia from her cluttered home. Her son and primary carer had hoarding disorder, OCD and Asperger’s syndrome. This leading case established the ‘five core categories’ of information a person must understand, retain and weigh to have capacity regarding possessions:
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• volume: amount of belongings and impact on room function
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• access: ability to use the property safely
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• hazards: fire, trip or unsanitary risks
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• safety: structural and general safety
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• disposal: need for and process of removing hazardous levels of belongings.
Case 3: It’s the contents of the jar that matter, not the label
The experts in Dudley Metropolitan Borough Council v Mailley [2022] agreed that the defendant’s hoarding behaviour was relatively severe but disagreed that hoarding disorder should be diagnosed. One attributed the behaviour to depression rather than a separate disorder; the other relied on its absence from ICD-10. The court was unpersuaded by either rationale.
Case 4: Best-interests intervention
A local authority sought temporary removal of a resident with severe hoarding disorder and OCD so that her home could be decluttered and deep cleaned (A Local Authority v X [2023]). The court held that her condition impaired her ability to weigh the serious fire and health risks. A best-interests intervention was justified despite her wish to remain at home.
Case 5: Proportionate legal action
In the case of Thiam v Richmond Housing Partnership [2025], a social landlord sought possession for rent arrears, anti-social behaviour and excessive hoarding. The tenant, whose hoarding was linked to systematised delusions, argued that eviction was discriminatory under the Equality Act 2010. Although the court accepted the connection with disability, it held that eviction was a proportionate means of protecting public health, housing stock and safety.
Conclusion
The case law establishes that assessments of people who hoard must balance respect for personal autonomy with safeguarding against serious risks arising from self-neglect and unsafe living conditions. Capacity assessments should focus on the ability to understand, retain, use and weigh information about possessions, their impact on access, hazards and the consequences of retaining or disposing of items. Where severe hoarding disorder, OCD or other comorbid conditions significantly impair decision-making, intervention in the person’s best interests may be justified. Disability-related hoarding does not preclude proportionate legal action where necessary to protect health, safety or effective housing management.
Acknowledgement
Artificial intelligence use: the author made use of Google AI Mode to research the origin of the epigraph which has been attributed by others to Einstein and to find sources of information on hoarding-related fires in England. Ministry of Housing Communities and Local Government (2026) was accessed from Google and used without modification on 18 Jul 2026.
Funding
This research received no specific grant from any funding agency, commercial or not-for-profit sectors.
Declaration of interest
None.
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