## Facts

- The dispute arose from an informal arrangement allowing Mr. and Mrs. Williams to occupy a cottage owned by Mr. and Mrs. Staite.
- The Williamses claimed they were given the right to occupy the property indefinitely based on assurances from the Staites.
- The Williamses argued that these assurances, alongside their financial contributions and extended occupation, created a constructive trust in their favour, granting them a proprietary interest.
- The Staites contended the arrangement was only a revocable personal licence, not conferring proprietary rights.
- Evidence considered by the court included oral assurances, the Williamses' financial contributions toward the property, and their continuous occupation over several years.

## Issues

1. Whether the informal arrangement and assurances between the parties created a constructive trust or only a personal licence.
2. Whether the evidence demonstrated a clear shared intention sufficient to establish a constructive trust and a proprietary interest for the Williamses.
3. Whether the Williamses' financial contributions and long-term occupation amounted to detrimental reliance supporting a trust.
4. Whether the arrangement could be revoked by the Staites and, if so, on what terms.

## Decision

- The court found that the evidence did not support the creation of a constructive trust in favour of the Williamses.
- The assurances provided by the Staites were too general and lacked clear, specific intention to create a trust.
- The Williamses’ financial contributions were not shown to be directly related to the purchase or improvement of the property.
- The arrangement amounted to a revocable personal licence, not a proprietary interest.
- The Staites retained the right to revoke the Williamses' licence to occupy the cottage, provided reasonable notice was given.

## Legal Principles

- A constructive trust arises where there is clear evidence of a shared intention to create a beneficial interest, detrimental reliance, and resultant detriment to the claimant.
- Vague assurances or indirect financial contributions are insufficient to establish a constructive trust.
- Licences confer only personal, not proprietary, rights and are generally revocable at the discretion of the licensor, provided reasonable notice.
- The burden of proof rests on the party alleging a constructive trust to provide clear, convincing evidence of shared intention and actual detriment.

## Conclusion

Williams v Staite [1979] Ch 291 demonstrates that informal property arrangements lacking unequivocal intention and direct financial contributions create only a revocable licence, not a proprietary right, highlighting the importance of formalizing property agreements to avoid uncertainty and protect rights.