<P> In urban properties, the location of the curtilage may be evident from the position of fences, wall and similar; within larger properties it may be a matter of some legal debate as to where the private area ends and the "open fields" start . </P> <P> The word derives from Middle English: courtelage; Old French: cortillage or cortil ("court, yard, garden"); cort (court) + - il (diminutive suffix) + - age (- age). </P> <P> At common law, which derives from English law, curtilage has been defined as "the open space situated within a common enclosure belonging to a dwelling - house ." Black's Law Dictionary of 1891 defined it as: </P> <P> "The enclosed space of ground and buildings immediately surrounding a dwelling - house . In its most comprehensive and proper legal signification, it includes all that space of ground and buildings thereon which is usually enclosed within the general fence immediately surrounding a principal messuage and outbuildings, and yard closely adjoining to a dwelling - house, but it may be large enough for cattle to be levant and couchant therein ." </P>

Which of the following is not a factor to be considered when determining curtilage