In 1972, Viscount Hailsham of St Marylebone said- ... the time may soon come when the whole sequence of cases based on promissory estoppel since the war ... may need to be reviewed and reduced to a coherent body of doctrine by the courts. I do not mean to say that they are to be regarded with suspicion. But as is common with an expanding doctrine, they do raise problems of coherent exposition which have never been systematically explored I Promissory estoppel has yet to receive serious attention from the Supreme Court of Canada, in spite of the fact that it has had several opportunities to provide a coherent exposition of this doctrine. The attitude of the Supreme Court is perplexing in light of the frequency with which this doctrine is raised in the lower courts. Both trial and appellate courts have disagreed over the nature of the doctrine and its availability as a cause of action.2 In spite of this discord, the Supreme Court has not used the opportunities that have arisen to provide guidance to the lower courts. The Supreme Court is not alone in this benign neglect of promissory estoppel. There is little discussion of the doctrine in the academic literature
