Central London Property Trust Ltd v High Trees House Ltd
[1947] KB 130
Ratio Decidendi
Where a party makes a promise intended to be binding, intended to be acted upon, and in fact acted upon, that party will not be permitted to revert to the original legal position as if the promise had not been made. This is the doctrine of promissory estoppel.
Ffeithiau
In 1937, Central London Property Trust let a block of flats to High Trees at £2,500 per annum. Due to wartime conditions reducing occupancy, the claimants agreed in 1940 to reduce the rent to £1,250. By 1945, the flats were fully let again. The claimants sought to recover the full rent for the last two quarters of 1945.
Crynodeb o'r dyfarniad
Denning J held that the full rent was payable from mid-1945 onward as the wartime conditions had ended. However, he stated obiter that had the claimants tried to recover the full rent for the war years, promissory estoppel would have prevented them. A promise intended to be binding and acted upon could not be revoked retrospectively.
Dyfyniadau allweddol
"The logical consequence no doubt is that a promise to accept a smaller sum, if acted upon, is binding notwithstanding the absence of consideration."
— Denning J
"The courts have not gone so far as to give a cause of action in damages for the breach of such a promise, but they have refused to allow the party making it to act inconsistently with it."
— Denning J
Triniaeth ddilynol
Leading authority on promissory estoppel. Applied in Tool Metal Manufacturing v Tungsten Electric [1955] and D & C Builders v Rees [1966].
Promissory estoppel operates as a shield, not a sword — it cannot found an independent cause of action (Combe v Combe [1951]).