Williams v Staite [1979] Ch 291

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.