Yeoman’s Row Management v Cobbe [2008] UKHL 55

House of Lords

Basic Facts : C and D had an oral agreement for property redevelopment. D withdrew after planning permission, leading C to claim estoppel.

Issue for the Court : Is unconscionable behavior enough to found a claim of estoppel?

Held :The court ruled that proprietary estoppel could not be invoked where there was no clear or unequivocal promise that gave rise to an expectation of a property interest.

Lord Scott (allowing the appeal)

  • Proprietary estoppel requires a proprietary claim and conduct that makes it unconscionable to deny the claim.

  • Mere expectation is insufficient; a clear legal or equitable interest must be shown.

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Kinch v Bullard [1998] 4 All ER 650

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Wrotham Park Estate Co v Parkside Houses [1974] 1 WLR 798