Facts
- Mr. Crabb owned a plot of land divided into two by a road owned by Arun District Council.
- Crabb sought access to the road to ensure both parts of his property could be used.
- The council initially indicated that they would grant him a right of way.
- Relying on that indication, Crabb sold the front portion of his land, leaving the remainder potentially landlocked.
- The council subsequently refused to formalize the right of way, thereby rendering the remaining land inaccessible.
- Crabb claimed that the council’s assurances created a binding obligation for the easement, invoking proprietary estoppel.
Issues
- Whether Arun District Council’s assurances and conduct created a right of way for Mr. Crabb over its land by proprietary estoppel.
- Whether Crabb’s reliance on the council’s assurances and the detriment suffered sufficed to make it inequitable for the council to deny the right of way.
- Whether proprietary estoppel could be invoked to create enforceable rights absent a formal written agreement.
Decision
- The Court of Appeal held that Arun District Council’s assurances and conduct amounted to a representation sufficient to found proprietary estoppel.
- The court found that Mr. Crabb had reasonably relied on the council's conduct by selling part of his property, leading to clear detriment in the form of landlocked land.
- It was considered unconscionable for the council to deny the right of way after encouraging Crabb’s reliance.
- Mr. Crabb was granted an easement by estoppel, enforcing his right of way across the council’s land despite the absence of a formal written contract.
- The judgment confirmed that equity could override statutory or formal legal requirements in such circumstances.
Legal Principles
- Proprietary estoppel prevents a party from denying rights where there has been an assurance, reasonable reliance, and resulting detriment.
- A clear assurance by a landowner, even if informal or implied, can form the basis for proprietary estoppel if the claimant acts to their detriment.
- Detriment includes actions such as property sales or any irreversible step taken in reliance on the assurance.
- The doctrine functions to prevent unconscionable conduct and to ensure fairness, potentially overriding formalities where justice requires.
- The judgment reaffirmed that equitable principles can create and enforce property rights even without a written agreement.
Conclusion
Crabb v Arun DC established that proprietary estoppel may grant an enforceable right of way when a party reasonably relies on a landowner's assurance to their detriment, even in the absence of a formal agreement, thus confirming the importance of equity in property disputes.