The presumption against intention to create legal relations applies to arrangements between an aunt/uncle and nieces/nephews, not only to arrangements between spouses or parents and children. The presumption applies with diminishing force the more remote the familial connection, but the fact that the parties were nieces and nephews rather than children does not necessarily assist in rebutting the presumption where the deceased regarded them as family. Vagueness of terms and informality of circumstances make it more difficult to rebut the presumption. For estoppel claims based on family promises to leave estates, the claimant must establish that the care provided was given in reliance on the representation rather than out of familial obligation, and that the care caused identifiable detriment to the claimant's personal or professional life.
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