The Court held that a public housing tenant's claim to a lifetime tenancy by estoppel failed on multiple grounds. The alleged representation that the tenant had security of tenure for life was characterised as promissory (relating to future conduct) rather than a representation of existing fact, meaning estoppel by convention or estoppel by representation was unavailable and only equitable estoppel could apply. The equitable claim was defeated by laches, specifically the tenant's acquiescence in entering successive leases on terms inconsistent with the claimed lifetime interest over a period of decades without ever asserting the lifetime entitlement. The Court also expressed doubt, without finally resolving, whether an equitable estoppel arising from dealings with a prior owner (the MSB) could bind a successor registered proprietor (the Housing Corporation) given s 42 of the Real Property Act 1900.
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