Jennings v Rice 
- The claimant (Jennings) worked as handyman for Rice. Over time, the claimant also looked after Rice, and for many years prior to Rice’s death, did so unpaid
- Instead of payment, Rice promised that her house and furniture would become the claimant’s on her death
- Rice died intestate
- Having found for the claimant on the grounds of proprietary estoppel, what value of award was the claimant entitled to?
- Rice’s house and furniture were collectively worth £435,000, but a proportional judgment between a claimant’s expectation and detriment must be made
- £200,000 was the judge’s calculation of the claimant’s detriment, and was a proportionate outcome
- Two principles were outlined to assist with satisfying the equity generated through proprietary estoppel:
- A court will only award the minimum equity to do justice
- Where character of reliance falls not far short of an enforceable contract, a claimant’s expectation may be fulfilled; but if not, the claimant’s expectation interest value will constitute the maximum value of the award
Posted in Land Law Revision Notes.
This page was last updated on 25th April 2015