A litter tray or toilet which may be used by a pet such as cat or dog has an upper section Figure 5, 1. The upper section has a perimeter wall with a circumferential hollow cut out open section. The tray has a bottom section, Figure 6, 2. The cavity or void of the upper section allows it to locate around an upstanding rim of the lower section, Figure 7. A liner, cover or lining may be placed on the interior of the base, the lining having a base and a substantially vertical sidewall that extends up the sidewall of the base of the litter tray. Thus, as the upper section of the tray is placed over the lower section the liner is held between the two sections. In use the side walls of the upper section protect the liner from damage by the claws or paws of the animal using the tray.
