판결 이유
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.
사실관계
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.
판결 요약
The House of Lords held that David Thorner had established a proprietary estoppel entitling him to the farm. Over many years David had worked long hours, unpaid, on his cousin Peter's farm, and Peter had led him to understand — largely through oblique and indirect words and conduct rather than any express promise — that David would inherit the farm on Peter's death. The House held that, for proprietary estoppel, an assurance need not be express or explicit: it is enough that the assurance was 'clear enough' in its context, judged by whether the claimant reasonably understood it as a commitment on which he was entitled to rely. Read against the background of their long relationship and the way farming families conduct their affairs, Peter's remarks were reasonably understood by David as an assurance that he would inherit the farm. David had relied on that assurance to his detriment by devoting himself to the farm for decades for little or no reward, and it would be unconscionable to deny him a remedy. The House distinguished Cobbe v Yeoman's Row, where sophisticated commercial parties knowingly proceeded without a binding agreement. Thorner is the leading modern authority on proprietary estoppel in the domestic and agricultural context.
주요 인용문
"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
후속 처리
Leading modern authority on proprietary estoppel in domestic/agricultural contexts.
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