Habberfield v Habberfield [2019] EWCA Civ 890

Facts

• The Habberfield family ran a dairy farm in Somerset, England.
• Lucy Habberfield worked on the farm from a young age, often without pay, believing she would eventually inherit the farm based on her father Frank Habberfield's repeated assurances.
• Following a family dispute, Frank sought to exclude Lucy from the farm’s ownership.
• Lucy claimed that her father's promises and her reliance on them created a binding obligation under proprietary estoppel.
• The High Court found in Lucy's favour, awarding her a lump sum of £1.17 million.
• Frank Habberfield appealed the High Court decision, contesting both the basis of the claim and the remedy awarded.

Issues

1. Whether there was a clear and unequivocal assurance by Frank Habberfield to Lucy regarding succession to the farm.
2. Whether Lucy relied on these assurances to her detriment.
3. Whether the remedy awarded was proportionate to the detriment suffered by Lucy in light of proprietary estoppel requirements.
4. Whether informal family arrangements and promises concerning agricultural property are enforceable through proprietary estoppel.

Decision

• The Court of Appeal found that Frank's assurances to Lucy were sufficiently clear to satisfy the requirement for proprietary estoppel.
• The court concluded Lucy had relied on these assurances, working for many years with limited pay and sacrificing other opportunities, resulting in significant detriment.
• The court considered the financial circumstances of the farm and interests of other family members when determining the remedy.
• The Court of Appeal upheld the High Court’s decision but adjusted the remedy to ensure it was proportionate to Lucy’s detriment.

Legal Principles

• Proprietary estoppel requires: (1) a clear assurance or promise, (2) reliance on that promise, and (3) detriment suffered as a result.
• The assurance must be sufficiently clear and unequivocal.
• Remedies must be proportionate, awarding no more than is necessary to address the detriment.
• Family farming arrangements based on informal promises can give rise to proprietary estoppel if the elements are established.
• The necessity of clear communication and formal agreements is highlighted to avoid disputes.

Conclusion

The Court of Appeal reaffirmed the key requirements for proprietary estoppel in the context of family farm succession, determining that sufficiently clear assurances coupled with substantial detrimental reliance justified a proportionate remedy in favour of Lucy Habberfield, while cautioning against reliance on informal family arrangements without formal agreements.