Is a canvasser who visits a private dwelling house a licensee?

In some decisions emphasis is placed on whether the premises visited are business premises or a private dwelling house. In Dunster v. Abbott, [1954] 1 W.L.R. 58, [1953] 2 All E.R. 1572, a salesman soliciting advertising orders from a potential customer at his private home was held to be a licensee. Denning L.J. said at p. 1574: “A canvasser who comes on your premises without your consent is a trespasser. Once he has your consent, he is a licensee. Not until you do business with him is he an invitee ... “In the present case the canvasser, the plaintiff, came to the door; the householder, the defendant, asked him in; the plaintiff stated his business; the defendant was not interested; and the plaintiff left. On these facts I am clearly of the opinion that the plaintiff was not an invitee, but only a licensee, because he was there on his own business and not on any matter in which the defendant had an interest. We all know that a guest whom a householder invites to dinner is only a licensee, even though the householder has an ulterior business motive in asking him. It would be strange if a householder owed a higher duty to a canvasser who comes unasked than he does to a guest who comes on his express invitation.”