Considers the House of Lords decision in Thorner v Major, reported as Thorner v Curtis, on whether a farmer who had worked without pay on his cousin's farm because of vague assurances that he would inherit the farm, had a claim in proprietary estoppel when the cousin died intestate. Discusses how the reasoning in the instant case differed from the earlier House of Lords decision in Cobbe v Yeoman's Row Management Ltd, the importance of certainty of representation and of the subject matter of the representation and the relationship between proprietary estoppel and constructive trusts
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