판결 이유
Where a common intention to share beneficial ownership is established (even if the expressed reason for not putting the property in joint names is false), and the claimant acts to their detriment in reliance on that intention, a constructive trust will arise.
사실관계
Mr Eves told his partner the house would be in his sole name only because she was under 21 (which was untrue). Relying on the implied promise of shared ownership, she made substantial contributions by doing heavy manual work on the property.
판결 요약
The Court of Appeal held that there was a common intention constructive trust. Mr Eves' excuse (her being under 21) implied that the house would otherwise have been in joint names. Ms Eves relied on this to her detriment by her significant physical contributions.
주요 인용문
"The man's excuse for not putting the property in joint names carried with it the implicit promise that the property was to be regarded as jointly owned."
— Lord Denning MR
후속 처리
Applied in Grant v Edwards [1986] on similar facts. Part of the line of authority on common intention constructive trusts developed further in Stack v Dowden and Jones v Kernott.