The Relationship Between the Constructive Trust and Proprietary Estoppel

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It has been asked in the given scenario to evaluate Neuberger LJ's approach to the relationship between the doctrines of the constructive trust and proprietary estoppel. To evaluate that, it is necessary to explain the definition of the constructive trust and proprietary estoppel .

Constructive trust is basically a form of trust which has been created by the courts where the defendant has dealt with proprietary in an "unconscionable manner", such as stealing or possessing it via fraud etc. Millet LJ in Paragon Finance Plc v DB Thakerar & Co (1998) EWCA Civ 1249, referred it as a trust which arises by operation of law whenever the circumstances are such that it would be unconscionable for the owner of property to assert his own beneficial interest in the property and deny it if another. It also arises when an owner ignores the rights of another person with an interest in that same property.

Proprietary estoppel is a legal principle which prevents someone, who has led another to believe in a particular state of affairs from illegally going back on the words which led to their belief. It arose in the case of Dillwyn v Llewelyn (1862), where a son spent £14,000 on building a house on the land with his father approval and promise that he would be in charge of that land but later found out that his father did not leave the property to him in his will. Lord Westbury held that the freehold int he land had been transferred to the son. However, four elements must be proved in order to claim for proprietary estoppel which are :

a) An assurance,
b) Reliance on that assurance,
c) Detriment,
d) Unconscionability .

In the case of Yaxley v Gotts (2000) ch 162, the defendant, Gotts bought a building to Yaxley, a self employed builder and in...

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...d acts tot heir detriment on the basis of trust. But there are some contradicting grounds between the two. Constructive trust is generally created by the action of the parties whereas a court order is mandatory in proprietary estoppel. Furthermore, the nature of constructive trust is to identify the true beneficial owner of the land and it reflects the nature of a person's interest but the court makes the minimum award which are essential to proceed for justice under proprietary estoppel, which allows the courts to provide such remedy fits to the facts of the case and the remedy is not necessarily be similar to the share in the beneficial ownership of the land to a monetary award.

However, judging from the points referred above, it can only be said that the two doctrines are still to a certain extent although the courts yet need to resolve other different traits.

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