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Jennings v Rice [2002]


  • 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?


  • £200,000


  • 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:
    1. A court will only award the minimum equity to do justice
    2. 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
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