Ramsden v Dyson
Lord Kingsdown's statement that a person who builds on another's land in the expectation of an interest, created or encouraged by the landowner, can enforce that expectation.
Facts
Tenants at will of land on Sir John Ramsden's estate in Huddersfield built on the land, believing that, following the practice of the estate, they would be granted long leases. Later owners of the estate refused to grant them leases on the terms they expected. The tenants claimed that they were entitled to long leases, because they had built in reliance on the expectation that leases would be granted.
Legal principle
The House of Lords, by a majority, held that the tenants were not entitled to leases, because the evidence did not show that the landowner had created or encouraged the specific expectation. However, Lord Kingsdown's dissenting speech became the classic statement of proprietary estoppel. He said that if a man, under a verbal agreement with a landlord for a certain interest in land, or under an expectation, created or encouraged by the landlord, that he shall have a certain interest, takes possession of land with the consent of the landlord and, on the faith of that promise or expectation, lays out money on the land, a court of equity will compel the landlord to give effect to that promise or expectation.
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
- Davies v Davies [2016] EWCA Civ 463
- 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
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