In a recent High Court decision, a son’s lifelong commitment to his family’s farm, based on his father’s assurances that he would inherit it, has resulted in a successful proprietary estoppel claim against his late father’s estate.
The case of Spencer v Spencer [2023] EWHC 2050 (Ch) highlights the legal principle of proprietary estoppel, which can provide a remedy when someone has relied on a promise to their detriment, even if that promise was not formally documented.
Michael Spencer had worked on his father John’s farm in Lincolnshire since the age of 15, often putting in 19-20 hour days. Despite a difficult relationship with his father, Michael stayed committed to the farm because John repeatedly assured him that he would inherit it one day. John told Michael things like, “You work hard. It will all be yours one day.”
However, when John passed away in 2018, his last will placed the farm in a discretionary trust, rather than leaving it directly to Michael as promised. Michael brought a proprietary estoppel claim against his father’s estate.
The High Court found that John’s assurances to Michael amounted to a “quasi-bargain” – in exchange for Michael’s commitment and hard work on the farm, he would inherit the land. By working hard on the farm for decades and positioning his life around the expectation of an inheritance, Michael had relied on his father’s assurances to his detriment. It would be unconscionable to allow John’s estate to go back on the promise.
The Court ordered that Michael should inherit the farmland, minus certain quarry land which had development potential. It was never part of the arrangement that Michael would receive land for its non-agricultural value.
This case is an important reminder that proprietary estoppel claims can provide an avenue for family members to enforce promises of inheritance, even in the absence of formal documentation. If you have worked for years on a family farm or business based on assurances that you will inherit, only to find yourself empty-handed, you may have a claim.
At C-PAID, we specialise in referring inheritance dispute cases to expert No Win No Fee solicitors. If you think you may have a proprietary estoppel claim, don’t hesitate to contact us on 0161 532 8111 or leave your details on our contact form for a free case assessment. Time limits may apply, so it’s important to seek advice promptly.
