Campbell v Griffin [2001]

1. Facts

• Background: Campbell (C) claimed promissory estoppel (PE) based on an assurance from Griffin (D) related to the management of certain properties. C admitted that his assistance to the landlords was driven more by compassion than by reliance on the promise.

• Issue: The central question was whether PE could be upheld despite C’s admission that his actions were influenced by compassion as well as reliance on the promise.

2. Outcome

• Court Decision: The Court of Appeal upheld the claim of promissory estoppel.

• Reasoning

◦ Dual Motive: The court acknowledged that C's motivation included both compassion and reliance on the promise. This dual motive did not invalidate the claim for PE.

◦ Reliance and Causation: Lord Walker emphasised that reliance should be seen as an issue of causation, specifically applying the 'but for' test. The court focused on whether the promise played a significant role in C's decision to act, rather than exclusively on the motive behind the actions.

3. Impact and Analysis

• Application of PE:

◦ Dual Motive: Campbell v Griffin demonstrates that promissory estoppel can be upheld even when a claimant has multiple motives for their actions. The presence of both reliance on the promise and other motivations, such as compassion, does not negate the applicability of PE.

◦ Causation Focus: Lord Walker’s approach highlights that reliance should be evaluated through the lens of causation. The court’s emphasis on the 'but for' test ensures that the promise's influence on the claimant’s actions is recognised, even if other factors also played a role.

• Legal Principles:

◦ Dual Motive Recognition: The case confirms that the presence of dual motives (e.g., compassion and reliance) does not preclude the application of PE. This allows for a more nuanced understanding of how promises impact individuals’ actions.

◦ Causation Analysis: By focusing on the causation test, the court ensures that the impact of the promise is assessed in terms of whether it was a significant factor in the claimant’s decision-making process.

• Broader Implications:

◦ Flexibility of PE: This case underscores the flexibility of promissory estoppel in accommodating complex motivations behind a claimant’s actions. It prevents unjust outcomes where the promise's influence is significant, even if other reasons also contributed.

◦ Equitable Relief: The decision reinforces the principle that equitable relief can be granted based on the impact of a promise, recognising the multifaceted nature of human decisions and actions.