What is promissory estoppel in High Trees?

If one party promises to accept less and the other relies on it, the promisor can be stopped from going back during that period, when it would be unjust.

Could the landlord restore full rent?

Yes, after wartime conditions ended and flats refilled, restoring the original rent for the future was not unjust.

Was the rent reduction permanent?

No. It was intended for the wartime downturn only, not forever.

Does estoppel create a new contract?

No. It prevents unfair enforcement of strict rights temporarily; it does not replace consideration rules.

central-london-property-trust-v-high-trees-house-ltd-1957

Central London Property Trust v High Trees House Ltd ([1957] 1 KB 130)

Promissory estoppel and rent reductions — an easy, classroom-style brief with timeline, IRAC, mnemonics, and FAQs.

King’s Bench Division 1957 Denning J [1957] 1 KB 130 Contract (Promissory Estoppel) ~7 min read

Author: Gulzar Hashmi · India · Published: 26 Oct 2025

Quick Summary

During World War II, the landlord agreed to take half rent because the flats were hard to fill. After the war, when occupancy returned, the landlord asked for the full rent going forward. The court said: the wartime reduction was protected by promissory estoppel for that period, but once conditions changed, the landlord could reinstate full rent for the future.

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Issues

Can a landlord claim the original rent after agreeing to a temporary reduction?
When does promissory estoppel prevent enforcing strict rights?

Rules

Promissory Estoppel

If A promises to relax a right and B relies on it, A may be stopped from going back on that promise for as long as reliance makes it unfair.

Reinstating Rights

A waived term can be reinstated for the future when circumstances change and doing so is not unjust.

Facts (Timeline)

Timeline: rent reduced during wartime, restored after

1937: Lease of a block of flats at £2,500/year.

1940: War + heavy bombing → low occupancy. Rent reduced by half (no end date stated).

1940–1945: Tenant pays reduced rent; later, flats refill.

1945: War ends; landlord seeks full rent going forward.

Proceedings: Question: can full rent be claimed after the reduction period?

Arguments

Appellant / Landlord

The reduction was a temporary wartime arrangement.
When conditions improved, full rent should resume.
Recovering arrears during wartime would be unfair, but not future rent.

Respondent / Tenant

They relied on the reduction to survive the downturn.
Landlord should be estopped from demanding full rent for the reduction period.
Any change should be prospective, not retroactive.

Judgment

Held: The rent reduction bound the landlord for the wartime period because the tenant relied on it. After the war, with normal occupancy, the landlord could restore the full rent for the future.

Effect: No recovery of wartime arrears, but full rent payable after conditions improved.

Ratio Decidendi

When a party promises to accept less and the other party relies on that promise, it would be unjust to let the promisor enforce strict rights during the reliance period. Once reliance reasons end, rights may be reinstated prospectively.

Why It Matters

Foundation of promissory estoppel in modern contract law.
Shows how courts balance fairness with strict legal rights.
Important for rent concessions, fee waivers, and crisis-time adjustments.

Key Takeaways

Promise + Reliance = Estoppel (for that period).
Waiver can be temporary and later reversed for the future.
Courts avoid unjust windfalls from changed conditions.

Mnemonic + 3-Step Hook

Mnemonic: “Promise Held, Then Rights Rebuild.”

Promise Held: Reduction stands while reliance lasts.
Change Arrives: Conditions improve.
Rights Rebuild: Full rent resumes prospectively.

IRAC Outline

Issue

After agreeing to half rent, can the landlord later demand full rent again?

Rule

Promissory estoppel bars enforcement of strict rights during reliance; rights may be restored for the future when fair.

Application

Tenant relied during wartime; unfair to claim full rent then. After war, with full occupancy, fairness supports restoration.

Conclusion

Full rent payable prospectively; no wartime arrears.

Glossary

Promissory Estoppel: A fairness rule stopping a promisor from taking back a relied-on promise, for as long as fairness requires.
Waiver: Choosing not to enforce a right. It can be temporary.
Prospective: A change that applies to the future, not the past.