Legal Case Summary
Central London Property Trust Ltd v High Trees House Ltd [1947] KB 130
Summary: This case established the doctrine of promissory estoppel in English law, which prevents a party from backing out of a promise which the other party had relied on, even though the promise wasn’t supported by consideration.
Facts
In 1937, Central London Property Trust Ltd (CLPT) leased a block of flats in London to High Trees House Ltd (HTH) at £2,500 per year for 99 years. Due to the impact of World War II, there was a drastic under-occupancy of the flats in 1940. CLPT agreed to reduce the rent to £1,250. This halved rent was paid until the end of 1945. By then, London had largely recovered from the war and the flats were again fully occupied. CLPT then claimed for the full rent for the last 2 quarters of 1945.
Issue(s)
The key question was whether the agreement by CLPT to accept a reduced rent was legally binding, and thus not allowing them to request the full rent once the flats were fully occupied again.
Direction/Outcome
The court held that CLPT could not go back on its promise to accept reduced rent for the period when the flats were not fully occupied. This was held as a clear case of CLPT making a promissory representation that they intended HTH to rely on and thus were estopped from reneging. However, it was also held that once conditions went back to normal, the original agreement could be enforced and therefore the claim for full rent for the last quarters of 1945 was successful.
The High Trees case thus strongly established the principle of promissory estoppel in English law, i.e., once a promise is made and relied upon, it cannot be reneged on without agreement (even if not supported by consideration) if this would be inequitable. However, importantly, it was also stipulated by Lord Denning that the effect of such a promissory estoppel ‘is only suspensive’ — i.e., it only temporarily varied the rent payable — and does not permanently extinguish rights.
References
‘Central London Property Trust Ltd v. High Trees House Ltd,’ [1947] KB 130 (King’s Bench Division).
Elliot, Catherine & Quinn, Frances. ‘English Legal System,’ 10th ed. (Pearson Education, 2009) 129-130.
Updated 13 March 2026
This article remains broadly accurate as a summary of the High Trees case and its significance in establishing promissory estoppel in English law. The legal principles described — that a clear and unambiguous promise, relied upon by the promisee, may prevent the promisor from reverting to strict legal rights for the period of reliance, and that the effect of promissory estoppel is generally suspensive rather than extinctive — continue to represent the orthodox position in English contract law.
Students should be aware that the doctrine has been significantly developed and refined by subsequent case law. Key authorities worth reading alongside High Trees include Tool Metal Manufacturing Co Ltd v Tungsten Electric Co Ltd [1955] 1 WLR 761 (confirming the suspensive nature of promissory estoppel and the conditions for resuming strict rights), D & C Builders Ltd v Rees [1966] 2 QB 617 (the doctrine requires the promisee to have acted equitably), and Collier v P & MJ Wright (Holdings) Ltd [2007] EWCA Civ 1329 (a more recent Court of Appeal decision touching on the boundaries of the doctrine in part-payment contexts). The principle that promissory estoppel can only be used as a shield and not a sword (i.e., as a defence rather than a cause of action) remains the prevailing English law position, though this continues to generate academic debate. The textbook cited in the references is now considerably out of date and students should consult a current edition of a standard contract law text.
