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Droit Immobilier

According to Article L

📅 Décision du 12 December 2012⚖️ Cour de cassation📖 2 min de lecture

According to Article L. 771-1, now L. 7211-2 of the Employment Code, referred to in Article 18 of the national collective agreement for caretakers, concierges and building employees of 11 December 1979, in its then applicable version, caretakers, building employees or cleaners of residential buildings are considered to include all persons employed by the owner or by the principal tenant who, living in the building as an incident of their employment contract, are responsible for its security, supervision and maintenance or some of these functions. It follows that an employee engaged under the statutory scheme for caretakers and assigned to the derogatory Category B scheme, which excludes any reference to specific working hours, must be lodged as an incident of his employment contract in the building where he performs his duties, which implies the allocation of a service accommodation.

Reference decision: cc • N° 11-20.653 • 2012-12-12 • Consult the decision →

This decision provides important clarification on your property law. Here is what it changes for you.

The situation

According to Article L. 771-1, now L. 7211-2 of the Employment Code, referred to in Article 18 of the national collective agreement for caretakers, concierges and building employees of 11 December 1979, in its then applicable version, caretakers, building employees or cleaners of residential buildings are considered to include all persons employed by the owner or by the principal tenant who, living in the building as an incident of their employment contract, are responsible for its security, supervision and maintenance or some of these functions. It follows that an employee engaged under the statutory scheme for caretakers and assigned to the derogatory Category B scheme, which excludes any reference to specific working hours, must be lodged as an incident of his employment contract in the building where he performs his duties, which implies the allocation of a service accommodation.

What the law says

This decision confirms the fundamental principles of property law.

Key takeaways

  • Strictly comply with the statutory time limits for appeals
  • Keep all supporting documents (title deeds, deeds, correspondence)
  • Anticipate: preventive advice always costs less than litigation

For an analysis of your situation: 30-minute consultation at €45 with Maître Zakine.

📌 Does this apply to your situation? Maître Cécile Zakine, French real estate lawyer, practises throughout France.
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Informations juridiques

  • Numéro: 11-20.653
  • Juridiction: Cour de cassation
  • Date de décision: 12 décembre 2012

Mots-clés

droit immobilierjurisprudenceimmobilier

Cas d'usage pratiques

1

Landlord employs caretaker without providing accommodation

Mr Dubois owns a 15-flat building in Lyon and employs a part-time caretaker under the national collective agreement, Category B, to handle security and minor maintenance. The caretaker lives in a rented studio elsewhere in the city. The employment contract makes no mention of a lodge.

Application pratique:

Under the 2012 ruling, a Category B caretaker must be lodged as an incident of employment. Mr Dubois should immediately review the caretaker's contract and either provide a service accommodation (e.g. a vacant ground-floor flat) or reclassify the role outside the statutory caretaker scheme. Failure to comply could lead to a claim for backdated housing costs and damages before the employment tribunal. He should consult a French real estate lawyer to regularise the situation.

2

Property manager hires concierge without a lodge

A co-ownership syndicate in Paris, represented by a property management firm, employs a concierge for a 25-apartment residence under Category B with flexible hours. The building has no caretaker's lodge, so the concierge works from a small office and lives 10 km away.

Application pratique:

The ruling confirms that Category B concierges are entitled to accommodation as part of their employment. The property manager must advise the co-owners to allocate a service flat in the building or convert an existing space into a lodge. If that is impossible, they should renegotiate the employment as a standard maintenance worker not covered by the statutory scheme. Acting now avoids costly litigation and social charges adjustments.

3

Caretaker denied accommodation despite Category B status

Ms. Ribeiro, employed for three years as a Category B cleaner in a residential building in Nice, has never been provided with accommodation; she rents a small flat 5 km away. Her payslips show no housing allowance or benefit in kind. She recently learned about the statutory lodging right.

Application pratique:

She can rely on this case to claim that her employer breached the collective agreement by not providing a lodge. She should gather her employment contract, pay slips, and proof of her own rent, then send a formal letter to the employer requesting either accommodation or compensation for housing costs. If refused, she may file a claim with the employment tribunal (conseil de prud'hommes) seeking back pay and damages. Legal aid or a union representative can assist with the process.

Maître Cécile Zakine

À propos de l'auteur

Maître Cécile Zakine — Avocate au Barreau des Alpes-Maritimes, Docteur en Droit. Chaque article de ce magazine est rédigé à partir de l'analyse d'une décision de jurisprudence réelle, commentée et mise en perspective par les équipes de Maître Zakine.

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