Central London Property Trust Ltd v High Trees House Ltd [1947]

Court: Court of Appeal

Facts: High Trees House Ltd leased a property from Central London Property Trust Ltd in 1937, with an annual rent of £2,500. Due to World War II, High Trees struggled with occupancy and requested a rent reduction, which was agreed upon in writing but without specifying duration or consideration. After the war, when occupancy increased, Central London Property Trust sought to claim the full rent from 1940 onwards.

Issue: Can a promise to reduce rent, made without formal consideration, be enforced when the conditions leading to the promise (e.g., wartime occupation issues) change?

Held: The Court of Appeal held that the promise to reduce the rent was enforceable during the wartime period but ceased to apply once the conditions changed and the property was fully occupied in 1945. The court introduced the doctrine of promissory estoppel, stating that a promise intended to be legally binding and acted upon prevents the promisor from going back on the promise.

Key Judicial Statement: Denning J stated, "A promise intended to create legal relations and acted upon cannot be reneged upon." He acknowledged that promissory estoppel allowed the enforcement of promises even without formal consideration if the promisee had acted on the promise.

💡Leveluplaw: The doctrine of promissory estoppel allows for the enforcement of promises even without formal consideration if the promise was intended to be legally binding and acted upon. This case highlights how equity can enforce promises made in response to changed circumstances, reflecting a departure from traditional contract law requirements.