Habberfield v Habberfield [2019] EWCA Civ 890

KEY POINTS

• Proprietary estoppel arises when one party makes assurances to another, who then reasonably relies on those assurances and suffers a detriment as a result. In this case, the court recognized the claimants' detrimental reliance and their equitable entitlement to relief.
• Proprietary estoppel is a flexible remedy that can be tailored to achieve fairness in the circumstances.
• The relief should reflect the value of the claimants' work and the impact of their expectations on their overall position.

FACTS

• From 1975, Frank and Jane farmed Woodrow farm in partnership, focusing on dairy farming. Lucy, their daughter, joined the farm full-time after leaving school and played a significant role in the development of the dairy farming business.
• Over the years, Frank made assurances to Lucy that she would inherit the farming business, subject to certain qualifications. Lucy relied on these assurances, dedicating her time and efforts to the farm, even passing up other opportunities.
• In 2008, an offer was made for a new partnership, but Lucy rejected it due to concerns about lack of control and interference from her siblings. Tensions within the family escalated, resulting in a fight between Lucy and her sister Sarah in 2013, after which Lucy and her partner Stuart resigned.
• Following Frank's death in 2014, Lucy initiated a legal claim seeking the transfer of the farm and farming assets based on the assurances made to her and the detriment she suffered as a result of her reliance on those assurances.

COMMENTARY

• This case highlights the court's willingness to recognize and enforce proprietary estoppel in family farming contexts, ensuring that individuals who have worked on family farms with expectations of future ownership are not left without recourse.
• The judgement emphasises the court's discretion in crafting relief that achieves a fair outcome based on the particular circumstances of the case, taking into account the claimants' contributions, expectations, and the overall value of the farm.