The requirement of writing in the Law of Property (Miscellaneous Provisions) Act 19891 may also not apply where claims are based on proprietary estoppel, which is often argued as an alternative where it is not possible to show the common intention needed to establish constructive trusts. An estoppel may arise where a property owner makes a representation to another party which is relied on by that other party and which leads that other party to act to their detriment2. The representation usually relates to the current or future ownership of land or of interests in land. If the party
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