The doctrine of Promissory Estoppel was first developed in Hughes v Metropolitan Railway Co but was lost for some time until it was resurrected by Lord Denning in the leading case of Central London Property Trust Ltd v High Trees House Ltd.. No separate requirement of unconscionability. In Hughes v Metropolitan Railway Co. (1877) 2 App. types of estoppel; d. Explain why unconscionability is not a key element in all estoppels. In particular he remarked that the following rationes of Deane J in Muschinski v Dodds "repay careful reading" (his Lordship said they applied to proprietary estoppel as they do to constructive trusts): The fact that the constructive trust remains predominantly remedial does not, however, mean that it represents a medium for the indulgence of idiosyncratic notions of fairness and justice. Lord Scott of Foscote, with whom the other Lords agreed, described at length that someone who seeks to rely on proprietary estoppel must establish an actual or certain interest in the property to which he claimed a right. A form of Estoppel in which one party acts to his detriment on a misrepresentation of fact by another. Under English law, estoppel by, promissory estoppel and proprietary estoppel are regarded as 'reliance-based estoppels' by Halsbury's Laws of England, Vol 16(2), 2003. It can be used to prevent a plaintiff denying that a statement or set of facts are true where they had previously represented that they were. The court will only enforce this lack-of-consideration promise if and … It does not refer to misrepresentations of points of law, not to promises of future action (see: Promissory estoppel). Similar views was expressed in Durham Fancy Goods v Michael Jackson  2 QB 839, where Donaldson J. held that contractual relationship is irrelevant provided that there is “a pre-existing legal relationship which could, in certain circumstances, give rise to liabilities and penalties”. The Section reads as follows: “When one person has by his … The buyers accepted the delivery and invoice without objection. If however, the car salesman accepts one pound in consideration for the promise, the promise is binding and enforceable in court. "You have an excellent service and I will be sure to pass the word.". The main intention of this doctrine is to avoid injustice to anyone like the other laws. Fifth, no defence to the estoppel can be raised by A. In Cobbe v Yeoman's Row Management Ltd the House overturned the decision of a fairly heavy-weight Court of Appeal on the very issue of estoppel, thereby illustrating the level of confusion about the meaning of the doctrine. A representation can be made either by words or conduct in equitable estoppel. The party with the 'nol' is estopped from their non-disclosure, and is forced to impart it equitably. The parameters of this doctrine seem presently not to be clearly defined. A notable case occurred as a result of the Birmingham Six case where the House of Lords ruled in Hunter v Chief Constable of the West Midlands Police that issue estoppel applied. The landlord claimed that Carr could not rely on her promise since she had not acted on his promise because she would have entered into the lease without any such promise having been made. The Court, however, ruled that the Plaintiff’s claim would be dismissed for being filed beyond the limitation period. The contract itself gives rise to an estoppel: .... Promissory estoppel is a rule of evidence that prevents the promisor from denying the truth of statement which the promisee had relied. In Alan Co. Ltd V El Nasr & Import Co. (1972) 2 QB 18, Denning detained that detriment is not an essential element of promissory estoppel. Estoppel includes being barred by false representation or concealment (equitable estoppel), failure to take legal action until the other party is prejudiced by the delay (estoppel by laches), and a court ruling against the party on the same matter in a different case (collateral estoppel). A legally binding contract occurs when one party makes an offer and receives an acceptance from the other party. It claims that the person made a representation, intending another to reasonably rely on it, and out of fairness, it should be upheld. estoppel, which falls under the category of estoppel by representation, is applicable when one party to a contract promises the other, either by words or conduct, that he will not enforce his right under the contract wholly or partially. In Combe v Combe Denning elaborated on the equitable nature of estoppel by refusing to allow its use as a "sword" by an ex-wife to extract funds from the destitute husband. Subsequently the value of the pound fell quite dramatically in relation to Nigerian pounds. This concept was evolved by equity to bring or render justice even in any strict position of law. Estoppel is an equitable (as opposed to common law) construct and is therefore discretionary. Therefore, for a plea of promissory estoppel to succeed, there must be a change in circumstances of the promisee. There are limitations which must be satisfied to this doctrine which derived from both Lord Cairns in the case Hughes v Metropolitan Railway Co. (1877) 2 AC 439 and Denning LJ in the High Trees case. In the case of D & C Builders v Rees the courts refused to recognise a promise to accept a part payment of £300 on a debt of £482 on the basis that it was extracted by duress. It had been suggested that Hughes could be restricted to "relief against forfeiture" cases, but this was specifically rejected in the later cases. For example, in Dillwyn v Llewelyn in Chancery a father promised a property to his son, who took possession, expended a large sum of money on the house and otherwise improved the property. The sellers mistakenly sent an invoice stating price was payable in Nigerian pounds. The proof of possible detriment or prejudice, which will appear if the promisor is allowed to revert to his original promise, is required. The Doctrine of estoppel is an equitable doctrine in law. It remains unsettled whether promissory estoppel may arise in pre-contractual relationships. At the time the value of sterling and Nigerian pounds was equal. Spencer, Bower and Turner, The law relating to Estoppel by Representation, Butterworth and Co. Ltd., London, 1977, 3 rd edition. 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