Loss of Housing Commission accommodation can constitute substantial detriment for proprietary estoppel purposes even without precise quantification, as courts may take judicial notice that such accommodation carries subsidised rent and security of tenure. However, where a promise of accommodation for life is gratuitous, given in the context of a family relationship that has since broken down, and the claimant has failed to quantify her detriment, relief may be limited to a fixed period rather than enforcing the full expectation of lifetime occupation. The majority and dissent disagreed on whether the potential availability of public housing should reduce the relief granted.
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