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Comino’s story is not a simple tale of private property. The land is public. What the documents record is a long, conditional temporary emphyteusis, repeatedly revised and later traded through companies. This timeline distinguishes what the deeds and official records establish from what still needs to be disclosed.

The timeline

  1. 11 March 1960

    The colonial grant. Before Notary to Government Victor Miller, Eric James Thompson, Accountant General and Director of Contracts, signed for the Government of Malta. John Gaul signed for Comino Development Company Limited; the witnesses were Legal Secretary Denis Synge Stephens and Attorney General John Joseph Cremona. The deed records a 150-year temporary emphyteusis, with annual ground rent of £100, payable in advance. The term runs to 10 March 2110. MaltaToday has reported that Gaul was the British property owner behind the company and that the original grant covered both Comino and Cominotto. The certified original plan and notarial copy must be published before the full original boundary can be treated as settled.

  2. 22-28 March 1963

    The first revision. The modifying deed was again before Victor Miller. Edgar Mizzi, Commissioner of Land, signed for Government; Alfred Geoffrey Bird, authorised by company directors A. J. Gaul and R. M. Wilson, signed for Comino Development Company Limited. The witnesses were Accountant General Richard Soler and Deputy Attorney General Maurice Caruana Curran. MaltaToday reports that the Borg Olivier government restricted the foreshore element, removed a proposed Cominotto restaurant and reduced the concession to the areas around San Niklaw Bay and Santa Marija Bay. The exact deed date remains unresolved: the 1989 recital says 22 March, a 1975 annex says 23 March, and the supplied scan is labelled 28 March. The certified notarial entry is needed.

  3. 23 June 1975

    Partial recovery and revision under the Government of Malta. Deed No. 555 was signed before Chief Notary to Government Anthony Attard. Saviour Bonello signed for Government and Alfred John Gaul for Tourist Development (Malta) Limited, described in the deed as formerly Comino Development Company Limited. The deed records the 1975 restructuring, including a Lm9,000 settlement and the State’s waiver of earlier breaches. Its annexed ministerial exemption describes the instrument as a revision of the Comino and Cominotto emphyteutical concessions. It is a documented continuity point, not proof of every later assignment or change in control.

  4. 13 April 1989

    A defined additional grant, with conditions. Before Notary Vincent Miceli, Acting Commissioner of Land Adriano Gouder signed for Government and Hansjorg Schwegler signed for Comino Holdings Limited. It confirmed the earlier chain and granted additional land until 10 March 2110: 5,139 m² of building land, plus 83,499 m² of park land in two plots. The foreshore was expressly excluded from one of those park plots.

    The 1989 deed set the additional annual rent at Lm4,240, subject to review. It limited the building land to a holiday centre and ancillary uses, required tree planting and afforestation on the park land, retained Government inspection rights, required transfer reporting and kept planning and other statutory permits separate. It allowed a future holiday-centre expansion on park land only through a stated conditional route, including approval of the plans by the Commissioner of Land and a rent adjustment. The current rent calculation, payment history, plans and approvals have not been published.

  5. 17 June 1998

    Comino as a warning in Parliament. During a House debate on government land disposals, former Prime Minister Dom Mintoff recounted the Comino recovery: Government took the island back in a way nobody could legally challenge, collected money rather than paid compensation, and the only price was that a small piece of land remained tied to a 150-year emphyteusis. Opposition leader Fenech Adami insisted the original grant was made by the colonial government, not a Maltese one, and called it perpetual; the 1960 deed itself records a 150-year term. Both accounts are parliamentary debate, not deed evidence, but they match the transacted record: the 1975 restructuring and its Lm 9,000 settlement. Mintoff told the House the lesson was that government land should never again be given away without a parliamentary resolution.

  6. 1998-2003

    An earlier extension application stops. MaltaToday reports that Kemmuna Limited filed an application to extend the hotel in 1998 and that processing was suspended in 2003 after the architect did not submit the required documents within the applicable period. The public planning file should be read with the relevant deed plans before any conclusion is drawn about the site or its boundary.

  7. July 2019

    Hili Finance funds the Kemmuna acquisition. Hili Finance Company plc, a Hili Ventures subsidiary, announced an €80 million bond issue. Its public announcement said that the funds would be predominantly directed to acquiring Kemmuna Ltd, identified as the owner and operator of the Comino Hotel and Bungalows. This was a company transaction, not a sale of Government land. The complete later title, assignment and consent chain remains a disclosure question.

  8. 21 April 2020 - 15 July 2022

    The Six Senses proposal enters the planning and environmental system. HV Hospitality Ltd, part of Hili Ventures, lodged PA/04777/20 for redevelopment of the Comino Hotel and Bungalows at San Niklaw Bay and Santa Marija Bay. Andrew Forte is named for the applicant and Adrian Falzon of CS Design is the architect of record. The submitted team names Belvedere Architecture as lead architect, Arup for MEP and sustainability, TBA Periti for structures and Michel Desvigne Paysagiste for landscape. The ERA Board issued its EIA decision, EA/00001/21, on 15 July 2022. The public material confirms the decision and its later appeals, but not an individual voting record. The 2021 environmental material describes a 140-bed hotel at San Niklaw and serviced bungalows at Santa Marija, alongside pools, facilities and infrastructure.

  9. 15 July 2022 - 12 June 2024

    The first environmental appeal is dismissed. Din l-Art Ħelwa, Moviment Graffitti, BirdLife Malta and Friends of the Earth Malta appealed the ERA decision in PAB 208/22. The Environment and Planning Review Tribunal decided the case on 15 February 2024. The Court of Appeal (Inferior Jurisdiction), in case 12/2024, dismissed the further challenge on 12 June 2024. That sequence concerned the EIA decision. It did not end the later appeal against the planning permit.

  10. 22 November 2022

    Parliament tables two deeds. In reply to Parliamentary Question 3849, Economy, European Funds and Lands Minister Silvio Schembri tabled Paper No. 927. It contains copies of the 1975 concession and the 1989 extension. That was a useful disclosure, not a substantive House vote on either deed. No verified parliamentary vote has been located approving the 1975 concession or its 1989 extension. The papers did not publish the full earlier title record, all plans, later assignments, rent reviews or deed-specific approvals.

  11. April-July 2025

    Planning approval, then an organised appeal. The Planning Board approved PA/04777/20 on 24 April 2025, with eight votes in favour and one against. The formal decision was dated 9 June and published on 11 June. The appeal to the Environment and Planning Review Tribunal, PAB 234/25, was filed on 11 July by Moviment Graffitti, BirdLife Malta, Nature Trust - FEE Malta, Din l-Art Ħelwa, The Archaeological Society Malta, Friends of the Earth Malta, Ramblers’ Association of Malta, Għawdix, Wirt Għawdex and Azzjoni: Tuna Artna Lura. The Planning Authority filed a response. The appellants’ published account describes the proposal as a 140-bed luxury hotel, 16 villas and 44 pools. Those figures describe the challenged proposal and should be checked against the final official drawings as the appeal proceeds.

  12. May 2025

    Visitor management begins at the Blue Lagoon. A free online booking system was introduced to cap visitors at 4,000 at any one time, in three daily time slots. Boat and ferry operators challenged it and a court briefly suspended it, then refused to block it, holding that protection of the Blue Lagoon and Comino is “undoubtedly in the national and general interest”. The system resumed on 19 May.

  13. 11 November 2025 - 4 May 2026

    The tribunal upholds the permit, then the Court of Appeal sends it back. The Environment and Planning Review Tribunal dismissed PAB 234/25 and confirmed the permit on 11 November 2025. The appellants took the case to the Court of Appeal, D 84/2025. On 4 May 2026, Judge Mark Simiana annulled the tribunal’s decision and ordered reconsideration. The court found the tribunal had accepted the total existing footprint as its measuring baseline without distinguishing lawful from unlawful development: under the Local Plan, which limits redevelopment to what is “existing”, only lawful development can count. Which structures are lawful is now the central question the tribunal must decide, and reporting of the case notes that development predating 1978 is treated as lawful.

  14. February 2026

    The earlier tree-intervention permit is annulled. Newsbook reported that the Environment and Planning Review Tribunal revoked the earlier permit after finding that the required public-participation process had not been properly followed. The underlying development appeal remained a separate case. The tribunal decision and permit file should be published in full.

  15. June 2026

    Public access and the cap under pressure. Partit Momentum proposed halving the daily cap to 2,000 visitors, with 1,000 slots reserved for Maltese and Gozitan residents. A viral video showed MTA enforcement officers ordering beachgoers off a public rocky area of the Blue Lagoon. MTA chief Carlo Micallef blamed inexperienced staff, conceded public space “remains public”, and admitted he had never seen the carrying-capacity study that underpins the cap, a study still withheld under Cabinet privilege despite court criticism, with NGOs litigating its release.

  16. 7-19 August 2026

    A fresh ERA decision while the wider appeal continues. On 7 August, ERA approved a new preliminary environmental programme connected to the project, covering site preparation works including the removal and transplanting of around 800 trees. Martin Galea de Giovanni, the eNGO representative, was reported as the only member voting against; reporting also identifies Christopher Ciantar, the Opposition representative, as voting in favour. The individual attendance-and-vote record for the remaining members has not been published. Newsbook reported both the campaigners’ concern and the developer’s account of removals, transplants and replacement planting. The Malta Chamber of Scientists demanded answers before any machine reaches the island, questioning the water supply for 44 pools and warning against piecemeal assessment of the project’s cumulative impact. The Nationalist Party called on government to suspend the preparatory works until the appeal is decided, noting that its own appeals-reform consultation would require exactly that. The hearing in the challenge to the wider development permit was listed for 19 August 2026. This is an active process, not a final outcome.

What the deeds do, and do not, establish

Revisiting this concession is not expropriation. It is correcting a colonial injustice.

What Comino is

Comino is public land and a protected island. Its future cannot be decided through partial disclosure or by treating a concession as an unlimited private entitlement.

Records still missing from the public file: certified 1960 and 1963 deeds and plans; every schedule and plan to the 1975 revision; the 1989 Land Drawing 269/88 and annexes; every later transfer, assignment, sub-emphyteusis or consent; rent-review calculations and payments; the Commissioner or Lands Authority approvals for any park-land expansion; and the final PA and ERA drawings and conditions.

Sources and record status

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