Registered greens in England and Wales are now governed by the Commons Act 2006, but the fundamental test of whether land is a town and village green remains the same. Thus land can become a village green if it has been used for twenty years without force, secrecy or request ("nec vi, nec clam, nec precario"). Village green legislation is often used to try to frustrate development. Recent case law ("Oxfordshire County Council vs Oxford City Council and Robinson") makes it clear that registration as a green would render any development which prevented continuing use of the green as a criminal activity under the Inclosure Act 1857 and the Commons Act 1876. This leads to some most curious areas being claimed as village greens, sometimes with success. Recent examples include a bandstand, two lakes and a beach.