Davies v Davies
The court must assess a proprietary estoppel award by reference to the claimant's expectation and detriment, and must avoid a disproportionate result.
Facts
Eirian Davies worked on her parents' dairy farm in Wales for many years, for low wages, relying on their assurances that she would inherit the farm. Her relationship with her parents was turbulent, and she left and returned to the farm several times. The parents eventually changed their wills, and the relationship broke down completely. The trial judge held that she was entitled to an award of £1.3 million.
Legal principle
The Court of Appeal allowed the parents' appeal and reduced the award to £500,000. Lewison LJ said that there must be proportionality between the remedy and the detriment, and that the court is not limited to awarding either the claimant's expectation or compensation for the detriment. The judge had wrongly treated a wide expectation, which the evidence showed had fluctuated over time, as if it were fixed, and had failed to take into account the benefits that Eirian had received, such as accommodation.
Related cases on contracts for land and proprietary estoppel
- Cobbe v Yeoman's Row Management Ltd [2008] UKHL 55, [2008] 1 WLR 1752
- Crabb v Arun District Council [1976] Ch 179
- Dillwyn v Llewelyn (1862) 4 De GF & J 517
- Firstpost Homes Ltd v Johnson [1995] 1 WLR 1567
- Gillett v Holt [2001] Ch 210
- Guest v Guest [2022] UKSC 27
- Habberfield v Habberfield [2019] EWCA Civ 890
- Inwards v Baker [1965] 2 QB 29
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This summary is for study and revision and is not legal advice. Although our case summaries are checked for accuracy, we do not guarantee that they are free from errors or omissions. Always read the full judgment for the court's reasoning.
