Crabb v Arun District Council [1975]

Court: Court of Appeal

Facts: In Crabb v Arun District Council [1975] EWCA Civ 7, Mr. Victor Crabb had purchased 2 acres of land in Pagham. He believed he had access rights at two points, A and B, with A formalized through an easement and B being informally allowed by Arun District Council. The council later installed gates at both points, with assurances about continued access. Crabb sold part of his land, relying on access at both points. When the council demanded £3,000 for access at point B, Crabb sued, arguing that he had been assured of continued access.

Issue: Whether proprietary estoppel could enforce the informal promise of access at point B and if it gave rise to a cause of action despite the lack of a formal agreement or consideration.

Held: The Court of Appeal held that proprietary estoppel applied, and Crabb was entitled to a right of access at point B without paying compensation. The council's conduct had led Crabb to reasonably believe in his access rights, and equity required that the promise be enforced.

Key Judicial Statement: Lord Denning MR stated that proprietary estoppel could arise from conduct or words, even in the absence of a formal promise or consideration. He explained that proprietary estoppel does not depend on agreement but on conduct or words that lead someone to believe they have a right, and that equity will protect such a belief. Scarman LJ outlined the steps for establishing proprietary estoppel: identifying the equity, determining its extent, and providing appropriate relief.

💡 Leveluplaw: proprietary estoppel can enforce informal promises or representations about land, even without formal agreements or consideration. It demonstrates the flexibility of equity in addressing issues where strict legal rights might be unjust. The case underscores the importance of protecting reliance on promises related to land, especially when such promises lead to detrimental reliance. Proprietary estoppel ensures that informal assurances about land use can be binding, reflecting equity's role in mitigating harshness and upholding fair expectations.