A promise to transfer a burial licence, relied upon by the promisee in exercising the right to nominate a burial place, can give rise to an equitable estoppel by encouragement even though the detriment is non-financial in nature — the loss of the ability to control burial arrangements and the comfort of knowing one can be buried next to a spouse is sufficient detrimental reliance. Successive offers by a family member (first to make a burial plot available, then to transfer the licence) may be characterised as a gift followed by a separate unsupported promise rather than mutually dependent promises constituting a contract.
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