Knights v Wiffen [1870]
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Knights v Wiffen [1870] LR 5 QB 660 is a significant case heard in the High Court, notable for its exploration of estoppel in the context of the sale of goods. The case delves into the circumstances under which a party may be estopped from denying the transfer of property and the impact of deliberate inaction on establishing estoppel.
The defendant, having offered to sell sacks of barley to a third party, did not specify any particular sack from his granary. Subsequently, the third party, before taking delivery, sold a portion of the barley to the claimant. When the claimant sought confirmation of the transfer, the defendant assured him that upon receiving a forwarding note, he would dispatch the barley. Following the third party's bankruptcy, the claimant presented the forwarding note, but the defendant refused to deliver the barley. The central issues were whether the defendant was estopped from arguing that property had not passed to the claimant, and whether the claimant possessed any contractual rights against the defendant.
The court rendered a decision in favour of the claimant. It held that the defendant was estopped from denying that the claimant had property in the goods. The claimant had altered their position in reliance on the defendant's statement, specifically by deliberately refraining from taking steps to protect their legal position against the third party's bankruptcy.
The case establishes the principle that when an individual makes a statement with the intention or knowledge that the other party will rely on it, and this reliance leads to a change in the other party's position, an estoppel arises. This legal doctrine prevents the party making the statement from later presenting evidence in court that contradicts the facts presented in the initial statement.
The case underscores the significance of honouring statements made within the context of a contractual agreement. Moreover, it emphasises the legal consequences that may ensue when a party relies on such statements to their detriment. Importantly, the principle of estoppel is applied even when there is deliberate inaction on the part of the claimant, constituting a noteworthy change in position.
