## Facts

- The case involved a covenant concerning property, where the covenantor made promises but failed to satisfy the necessary formalities or complete the covenant.
- The court was required to determine whether this incomplete covenant could be enforced in equity.
- The context included historical developments in both common law and equity relating to covenants and the specific equitable rules on enforceability.
- Previous authorities such as Cannon v Hartley and Re Kay’s Settlement were referenced in relation to the enforceability of covenants in equity.

## Issues

1. Whether an incomplete covenant that lacks certain formalities can be enforced in equity.
2. Whether equity will intervene to enforce a covenant that does not clearly demonstrate a binding obligation.
3. Whether equitable remedies supplement common law when legal requirements for covenant enforceability have not been satisfied.

## Decision

- The court held that equity would not enforce a covenant that was incomplete or lacked the necessary formalities.
- It was determined that only covenants which are clear, complete, and show a genuine intention to create a binding obligation are enforceable in equity.
- The judgment emphasized equity as a supplement to common law, only intervening where common law is inadequate or unjust, but not to cure incomplete formalities in covenants.

## Legal Principles

- Equity will not enforce a covenant that is incomplete or lacking formal legal requirements.
- For equitable enforcement, there must be a clear and unambiguous intention to create a binding legal obligation.
- Equitable remedies act as a supplement—never a replacement—for the common law; strict formalities remain critical.
- Equity will not assist a volunteer; voluntary covenants, particularly those lacking consideration, are rarely enforceable unless clear and complete.
- The principles apply particularly in property law, trusts, and family settlements concerning the enforceability of promises or covenants.

## Conclusion

Re Pryce [1917] 1 Ch 234 established that incomplete covenants cannot be enforced in equity, reinforcing the necessity for formal completeness and a clear binding intention before equitable remedies will be available. Legal practitioners should ensure compliance with all formal requirements when drafting covenants to avoid unenforceability in equity.
