His reliance on long-standing promises made it unconscionable to deny him the land
The High Court upheld a decision granting a farm worker ownership of a property under proprietary estoppel, ruling that his reliance on long-standing promises made it unconscionable to deny him the land.
The farm worker began share farming on the property in 1975 after his father had entered a similar arrangement with the property’s owners. Under the informal agreement, the worker maintained the property, lived rent-free in a house on-site, and shared the costs and profits of the farming operations. Despite his significant efforts, his income remained minimal and irregular, often well below average earnings for comparable work. The property was small and commercially unviable, yet the farm worker remained committed to its upkeep.
In the 1980s, the property owner and her spouse made assurances to the farm worker about his future interest in the property. Initially, the promise was that he would receive a life interest in the land. Later, after the spouse was diagnosed with a terminal illness, the assurance changed, with the understanding that ownership of the property would pass to the worker after the surviving owner’s death. Following the spouse’s death in 1988, the surviving owner reaffirmed that the farm would pass to the worker, expressing admiration for his efforts and honesty.
In reliance on this promise, the worker continued his efforts on the property for another 23 years. The court found that he endured substantial detriment by maintaining the property for minimal financial return and forgoing alternative employment opportunities. He remained on-site despite poor living conditions, including inadequate facilities, vermin infestations, and a lack of basic amenities. Without the assurances of inheritance, the worker would have terminated the farming arrangement and sought higher-paying employment elsewhere.
Despite these long-standing assurances, the property owner’s final will, executed in 2011, left the property to her child. The worker received only a monetary legacy. Following the property owner’s death in 2016, the worker brought a claim seeking to enforce the promises made to him.
The trial court found in favour of the farm worker, holding that the promises and his detrimental reliance on them established a proprietary estoppel. The court determined that it would be unconscionable to deny him the property. The Court of Appeal upheld this decision, rejecting the estate’s arguments that liability under estoppel required further acts of encouragement after the promise or actual knowledge of the worker’s reliance.
On appeal to the High Court, the estate argued that proprietary estoppel required the property owner to engage in further acts of encouragement following the promise and to possess actual knowledge of the worker’s detrimental reliance. The High Court rejected both arguments, ruling that no further acts of encouragement were necessary when a promise had already been made. It was sufficient that the promise itself reasonably led to reliance. Similarly, the court held that actual knowledge of reliance was not required. It was enough that a reasonable person in the property owner’s position would have expected the promise to be relied upon.
The High Court emphasised that equity does not enforce promises directly but intervenes to prevent unconscionable outcomes when a promise induces significant detrimental reliance. In this case, the farm worker’s sacrifices, financial losses, and personal hardships, which were undertaken in reliance on the property owner’s assurances, justified equitable relief. The court dismissed the appeal and upheld the decision to hold the property on trust for the farm worker.
