Facts
- 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
Issue
- Having found for the claimant on the grounds of proprietary estoppel, what value of award was the claimant entitled to?
Decision
Reasoning
- 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
