In a proprietary estoppel by encouragement case where no express promise or representation is established, the expectation reasonably derivable from the defendant's conduct must be carefully delineated: an invitation to occupy and consent to improvements at the occupier's expense justifies an expectation of a right of residence for a substantial period, but not an expectation of inheritance or transfer of ownership. Where improvements have been enjoyed over a lengthy period of rent-free occupation, the expenditure may be regarded as amortised, limiting the relief to a licence of occupation during the property owner's lifetime.
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