Ruling court House of Lords | ||
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Citation(s) [1877] UKHL 1, [1877] 2 AC 439 Similar Central London Property, D & C Builders Ltd v Rees, Foakes v Beer, Pinnel's Case, Crabb v Arun DC | ||
Hughes v Metropolitan Railway Co [1877] is a House of Lords case considered unremarkable for many years until it was resurrected by Lord Denning in the case of Central London Property Trust Ltd v High Trees House Ltd in his development of the doctrine of promissory estoppel. The case was the first known instance of the concept of promissory estoppel.
Contents
Facts
Thomas Hughes owned property leased to the Railway Company at 216 Euston Road. Under the lease, Hughes was entitled to compel the tenant to repair the building within six months of notice. Notice was given on 22 October 1874 from which the tenants had until 22 April to finish the repairs. On 28 November, the tenant railway company sent a letter proposing that Hughes purchase the tenant's leasehold interest. Negotiations began and continued until 30 December, at which point nothing was settled. Once the six months had elapsed the landlord sued the tenant for breach of contract and tried to evict the company.
Court of Common Pleas
The Court of Common Pleas held in favour of the landlord, Mr Hughes. Metropolitan appealed. Lord Coleridge CJ delivered the leading judgment, with which Brett J and Lindley J concurred.
Court of Appeal
The Court of Appeal (1875–76) LR 1 CPD 120 reversed the decision of Court of Common Pleas. James LJ, Mellish LJ, Baggallay JA, Mellor J, and Cleasby B gave judgments.
House of Lords
The House of Lords affirmed the Court of Appeal. It ruled that with the initiation of the negotiations there was an implied promise by the landlord not to enforce their strict legal rights with respect to the time limit on the repairs, and the tenant acted on this promise to their detriment. Lord Cairns LC gave the lead judgment, with which Lords O'Hagan, Selborne, Blackburn and Gordon concurred.
In this instance the rights of the landlord were suspended only temporarily, allowing the tenant more time to repair.