D implied that he would leave his farm to P in his will. P had worked for free on D’s land for many years for free, and D had entrusted P with money to pay death duties etc. He entered P in his will as implied, but, due to an argument with another relative who stood to inherit a separate asset, tore it up and died intestate. P claimed that he acquired the rights to the farm via proprietary estoppel, and the HL allowed his claim.
Lord Walker: Proprietary estoppel is a means of acquiring rights, but that the agreement had to be ‘sufficiently certain’ (however he did not repeat the claims from Yeoman’s Row v Cobbe that the agreement had to be ‘legally binding’ or ‘binding and irrevocable’). This is still a high threshold, as in Crabb v Arun DC where negotiations were at a very advanced stage.