• In Suggit v Suggit, the Court of Appeal stated that it is not necessary to, in a successful proprietary estoppel claim, grant relief proportionate to the claimant’s detriment.
  • It must be noted that this case has since been overruled by Habberfield v Habberfield.

 Facts of the case

  • C worked on his father’s (F’s) farm.
  • F promised C that he would inherit his farm upon F’s death, and C went so far as to structure his whole life around this promise.
  • Despite this, F, after being dissatisfied with his son’s ability to operate the farm, left the farm to his daughter instead.
  • The son argued that he should have the farm under proprietary estoppel, and the trial judge granted him it.

Issues in Suggit v Suggit [2012]:

  • the court had to determine whether there was indeed proprietary estoppel on the facts, and if so, what level of relief should be granted.

Court of Appeal (CA) held:

  • The CA found in favour of C and thereby allowed him to have the entirety of the farm.
  •  His reasoning was that Jennings v Rice was not precedent for the detriment being proportionate to the relief granted, but rather, it was precedent for the relief not being all out of proportion to the relief. On this basis, he held that the farmland was not all out of proportion to the detriment suffered by the claimant in reliance on his father’s promise. He respect the judge’s decision with respect to this.

Walker LJ:

  • [38] “In my judgment, the judge was entitled to hold that there was sufficient reliance and detriment. I accept that the burden on John was to show these matters and that the judge took a very realistic assessment of the work he had done. He held that the work he had done was not as heavy, or as onerous, as a farm labourer would have done and that in addition the farm labourer would have to have paid his own living expenses.”
  • [44] “In my judgment, this principle does not mean that there has to be a relationship of proportionality between the level of detriment and the relief awarded. What Walker LJ holds in this paragraph is that if the expectations are extravagant or “out of all proportion to the detriment which the claimant has suffered”, the court can and should recognise that the claimant’s equity should be satisfied in another and generally more limited way. So the question is: was the relief that the judge granted “out of all proportion to the detriment” suffered?”
  • “[45] I do not consider that to grant him the farmland, whatever that means, could be said to be out of all proportion.”

Editor’s note:

  • NB: This judgment has been overruled by Habberfield v Habberfield, and so it is only useful for demonstrating how the law has developed, and for analytical purposes insofar as saying whether it was in need of change and why, and which approach was better.

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