Gillett v Holt [2001] Ch 210

Court: Court of Appeal

Basic Facts:

• Parties: C (Claimant), D1 (Landowner), D2 (New Beneficiary).

• Context: C managed D1’s farm and was promised succession to the business and farmhouse. After D1's death and a change in dispositions to D2, C claimed proprietary estoppel.

Issue for the Court: When can proprietary estoppel be established?

Held: The court ruled that proprietary estoppel could arise from repeated assurances over many years, even in the absence of a formal agreement, if the claimant had detrimentally relied on them.

Walker LJ

• Assurances: Estoppel depends on the context, and promises must be clear and repeated. Detrimental reliance on these assurances is crucial.

• Detriment: Not limited to financial loss but includes substantial changes in position based on reliance on the promise. C’s loss of other opportunities and personal sacrifices constituted detriment.