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Attorney-General of Hong Kong v Humphrey’s Estate [1987]


  • The Government agreed to acquire some flats from the defendant group
  • Early possession was granted to the Government, who spent money improving them
  • The agreement documents were marked ‘subject to contract’


  • Could proprietary estoppel operate?


  • No


  • The marking ‘subject to contract’ evidenced that negotiations were ongoing, so the Government improved the flats in the mere hope that negotiations would be concluded, when in fact there were not
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