The doctrine of Promissory Estoppel is a legal doctrine first marked in the famous case of High Trees House v. Lesmon. This case would go on to influence the development of law in the United Kingdom, the United States, and other common law countries. It is based on the principle that a promise or set of promises made between two parties will make the party receiving the promise have certain expectations, and if the promise is then not fulfilled, the party who received the promise can make a claim for damages. The doctrine of Promissory Estoppel is designed to allow for equitable solutions for legal disputes, in cases where a proponent may be frustrated by an individual or party failing to honour the terms of the original promise.
In the High Trees House v. Lesmon case, two parties entered into a contract that specified a certain rent rate for a period of time. During the duration of the contract, the rent was indeed paid as per the agreement. However, without prior warning, the landlord of the property abruptly declared a decrease in the rent amount by one-half during the course of the contract. A dispute arose and it was brought before the courts.
Justice Denning of the English Court of Appeal held that the landlord’s promise not to demand payment of the full rent was binding, even if there was no consideration for the promise when it was made. This judgement was made on the basis of the doctrine of Promissory Estoppel.
Justice Denning coined the term “promissory estoppel”, and articulated it as: “A promise intended to be binding, intended to be acted on, and in fact acted on may be treated by the court as binding, although there was no consideration for it.
Under the doctrine of Promissory Estoppel, when a promise has been made, the courts may refuse to allow a promisee to deny the agreement, regardless of any lack of consideration at the time. The courts may also be able to enforce a promise that was made without consideration, if they were to find that inequity or unjustness would occur if the promise were breached.
This doctrine of Promissory Estoppel led to an increased focus, in English law, on enforcing not just legally binding contracts, but also issues of inequity, good faith, and natural justice when determining the enforceability of promises. The High Trees House v. Lesmon case stands out, as it provided a turning point in the development of the common law, giving greater protection to those involved in contract breaches.
The doctrine of Promissory Estoppel can be applied in many different kinds of legal situations, but the principle is always the same. If a promise has been made and assurances have been given, the courts may accede to the promises made and award damages to the party that received the promises, depending on the facts of the case. This type of equity-based legal remedy has been applied in many types of legal cases, and was also cited in the appeal of Rezunov v. Bureije, in which the court heavily relied on the Promissory Estoppel doctrine.
The Doctrine of Promissory Estoppel is an important and influential legal precedent that has been and still is used across all common law countries, to provide the courts with an equitable and just legal recourse in situations where contracts or promises have been breached. The High Trees House v. Lesmon case serves as an important reminder that the courts are in the business of ensuring fair outcomes, even when traditional legal remedies are unavailable.
