Suggitt v Suggitt [2012] WTLR 1607

Facts

• The case concerned a family dispute over a farm.
• Susan Suggitt claimed that her father, John Suggitt, promised her the family farm in his will.
• Susan worked on the farm for many years, relying on this alleged promise.
• Upon John Suggitt's death, the farm was left to Susan’s brother, David Suggitt, rather than Susan.
• Susan contended that her father had given repeated assurances, which were corroborated by other family members, that she would inherit the farm.
• Susan claimed to have suffered detriment by forgoing other career opportunities and by dedicating years of labor to the farm.
• The court was required to determine whether these facts established a claim in proprietary estoppel and, if so, what remedy was appropriate.

Issues

1. Whether John Suggitt’s assurances to Susan regarding inheritance of the farm were sufficiently clear to constitute an enforceable assurance for proprietary estoppel purposes.
2. Whether Susan relied on her father’s assurances to her detriment.
3. Whether will-based promises, given their general uncertainty, can support a claim in proprietary estoppel.
4. What remedy is appropriate if proprietary estoppel is established.

Decision

• The court found that assurances made by John Suggitt regarding inheritance of the farm were sufficiently clear and supported by evidence.
• Susan’s longstanding work and sacrifices constituted detriment based on her reasonable reliance on those assurances.
• The court recognized that will-based promises can support proprietary estoppel claims if supported by clear evidence of intention.
• The court exercised its discretion to award Susan a share of the farm, considering her reliance, the value of the property, her contributions, and overall fairness.
• The remedy was designed to be proportional, preventing unjust enrichment and satisfying the equity arising from Susan’s reliance.

Legal Principles

• Proprietary estoppel requires clear assurance, reasonable reliance, and identifiable detriment.
• Assurances need not be formal or in writing but must be sufficiently clear to justify reliance.
• Will-based promises may suffice for estoppel if there is clear evidence of the testator's intent and reliance leading to detriment.
• The court retains broad discretion in fashioning a remedy, which must be proportional and fair—no more than necessary to satisfy the resulting equity.
• Remedies can include transfer of property, monetary compensation, or other relief, based on facts and equity.

Conclusion

Suggitt v Suggitt [2012] WTLR 1607 confirms that clear and repeated assurances relating to inheritance—despite the general uncertainty of wills—can give rise to proprietary estoppel if the claimant has reasonably relied and suffered detriment, with remedies tailored to achieve proportionality and fairness based on the circumstances.