Ratio Decidendi
Proprietary estoppel can arise from indirect assurances. It is sufficient that the claimant reasonably understood the assurances to mean they would inherit property, even if the assurances were oblique rather than express.
Facts
David Thorner worked unpaid on his cousin Peter's farm for nearly 30 years in the expectation of inheriting it. Peter made indirect remarks suggesting David would inherit but never made a clear promise. Peter died intestate.
Judgment Summary
The House of Lords held David had established proprietary estoppel. The assurances, though indirect, were sufficiently clear in context and David had relied on them to his detriment.
Key Quotes
"What matters is not the precise words used but whether the assurances were reasonably understood as a commitment on which the claimant was entitled to rely."
— Lord Walker
Subsequent Treatment
Leading modern authority on proprietary estoppel in domestic/agricultural contexts.