Gillett v. Holt

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Gillett v. Holt The doctrine of proprietary estoppel is an equitable intervention in cases where the enforcement of legal rights is considered by the courts to be unconscionably unfair. The essence of the doctrine arises, as defined by Snell: '[when] one (A) is encouraged to act to his detriment by the representations or encouragement of another (O) so that it would be unconscionable for O to insist on his strict legal rights.' (McGhee, 2000, p.637) In the absence of a written agreement, estoppel acts as an evidentiary tool with which the courts can help ensure fair interaction in property dealings. Proprietary estoppel is a method by which informal arrangements are recognized as being capable of creating proprietary interests. Given that it lies within the domain of equity, the case law indicates a great flexibility in its application, both in the substantive requirements of proof demanded by the courts and in the manner in which the courts will satisfy the equity. It is the first of these aspects of the doctrine that I will examine in this essay. I will look at the shift in the evidentiary requirements and what a representation (or an assurance of rights), a reliance (a change of position on the basis of that assurance) and a detriment (or unconscionable disadvantage) - the three pre-requisites for a successful claim - have come to mean with regard to case law and in particular the judgement of Judge Robert Walker in the Court of Appeal in Gillett v. Holt[1], in which the plaintiff had been given repeated assurances over many decades that he would inherit the defendant's estate, and remained in service to him at least p... ... middle of paper ... ...operty, 16th Ed, Butterworths K. Gray & S.F Gray - Land Law, 2nd Ed, Butterworths Professor Cedric D Bell - Land: The Law of Real Property, 3rd Ed, Old Bailey Press --------------------------------------------------------------------- [1] (2000) 2 All ER 289, [2] QB 133 [3] (1965) 2 QB 29 [4] 15 Ch D 96 [5] Law Com. No. 164 (1987), para. 4.13 [6] pp. 149, 151-52 [7] 26 November 1987; Court of Appeal (Civil Division) Transcript No 1200 of 1987 [8] (2000) Ch 162 CA [9] (1993) 69 P & CR 170 [10] [1982] QB 84, 104-105 [11][1980] 1 WLR 1306 [12] [1976] Ch 179, 189, 198 [13] p. 224 [14] [1998] 1 FLR 806 [15] [1975] 3 All ER 768 [16] (2001) 48 EGCS 129 [17] (1996) 2 WLR 1498 [18] (1996) 72 P & CR 196, CA [19] 2nd ed (1993), p 324

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