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Central London Property Trust Ltd v High Trees House Ltd [1947] KB 130

📄 Case Briefs


“The promise to accept reduced rent was intended to be relied upon by HTH, and HTH did rely on it.” - Court of Appeal, Central London Property Trust Ltd v High Trees House Ltd (1947)

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UK Law Case Brief

  • Case Citation: Central London Property Trust Ltd v High Trees House Ltd [1947] KB 130
  • Jurisdiction Tags: Contract Law, Promissory Estoppel
  • Short Case Name: Central London Property Trust Ltd v High Trees House Ltd
  • Court/Level: King’s Bench Division


Contents:

  • Facts
  • Issues
  • Holding
  • Rationale
  • Rule/Principle Established
  • Introduction
  • Requirements
  • Remedies
  • Defences
  • Information for Journalists
  • Subsequent Applications
  • Further Reading
  • Cite This Summary


Facts

In 1937, Central London Property Trust Ltd (CLPT) leased a block of flats in London to High Trees House Ltd (HTH) at £2,500 per year for 99 years. Due to the impact of World War II, there was a drastic under-occupancy of the flats in 1940. CLPT agreed to reduce the rent to £1,250.


This halved rent was paid until the end of 1945. By then, London had largely recovered from the war and the flats were again fully occupied. CLPT then claimed for the full rent for the last two quarters of 1945.


Issues

The main legal issues in the case were:


  • Whether the agreement by CLPT to accept a reduced rent was legally binding.
  • Whether CLPT could request the full rent once the flats were fully occupied again.
  • Whether the doctrine of promissory estoppel applied to prevent CLPT from reneging on its promise.


Holding

The court held that CLPT could not go back on its promise to accept reduced rent for the period when the flats were not fully occupied. This was held as a clear case of CLPT making a promissory representation that they intended HTH to rely on and thus were estopped from reneging.


However, it was also held that once conditions went back to normal, the original agreement could be enforced, and therefore the claim for full rent for the last quarters of 1945 was successful.


Rationale

The court reasoned that the promise to accept reduced rent was intended to be relied upon by HTH, and HTH did rely on it. The court emphasized that promissory estoppel prevents a party from going back on a promise which the other party has relied upon, even if the promise was not supported by consideration. However, the effect of promissory estoppel is only suspensive, meaning it temporarily varies the rent payable and does not permanently extinguish rights.


Rule/Principle Established

The case established the doctrine of promissory estoppel in English law, which prevents a party from backing out of a promise which the other party had relied on, even though the promise wasn’t supported by consideration. The effect of promissory estoppel is suspensive and does not permanently extinguish rights.


Introduction

The case relates to the legal concept of promissory estoppel, which is a principle in contract law that prevents a party from reneging on a promise that the other party has relied upon. It addresses the issue of whether a promise to accept reduced rent can be enforced even if it was not supported by consideration.


Requirements

The requirements for promissory estoppel include a clear and definite promise, reliance on the promise by the other party, and it being inequitable for the promisor to go back on the promise. The promise must be intended to create legal relations and must be acted upon by the promisee.


Remedies

The remedy in this case was the court’s order that CLPT could not claim the full rent for the period when the flats were not fully occupied, but could claim the full rent once conditions returned to normal. This recognized the binding nature of the promissory representation and the reliance by HTH.


Defences

CLPT’s defence was based on the argument that the promise to accept reduced rent was not legally binding and that they could claim the full rent once the flats were fully occupied. This argument was partially accepted by the court, which held that the promise was binding during the period of under-occupancy but not thereafter.


Information for Journalists

The case is relevant and important for journalists because it demonstrates the legal principles and issues involved in promissory estoppel and contract law. It shows the role and function of the courts in interpreting and applying the law to the facts and circumstances of each case, and the possible outcomes and consequences of different judicial decisions. The case also illustrates the impact and influence of statutory law and regulation on contractual agreements and promises.


Subsequent Applications

The case has been applied and followed by subsequent courts in similar cases involving promissory estoppel and contract law. It serves as a precedent for future cases involving the binding nature of promises and the requirements for promissory estoppel.


Further Reading


Cite This Summary:

You can cite this summary using the following formats:


  • APA: Copilot, M. (2024). Central London Property Trust Ltd v High Trees House Ltd - Case Summary. Retrieved from https://artiwplus.com/blog/cases/central-london-property-trust-v-high-trees-house
  • MLA: Copilot, Microsoft. “Central London Property Trust Ltd v High Trees House Ltd - Case Summary.” https://artiwplus.com/blog/cases/central-london-property-trust-v-high-trees-house, 2024, https://artiwplus.com/blog/cases/central-london-property-trust-v-high-trees-house.
  • Chicago: Copilot, Microsoft. “Central London Property Trust Ltd v High Trees House Ltd - Case Summary.” https://artiwplus.com/blog/cases/central-london-property-trust-v-high-trees-house, 2024, https://artiwplus.com/blog/cases/central-london-property-trust-v-high-trees-house.


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