Crabb v. Arun DC, [1976] 1 Ch 179 (Court of Appeal). The requirements of Doctrine of Promissory Estoppel have also been formulated in ‘Chitty on Contracts’, 32nd Edition. Combe v. Combe, [1951] 2 KB 215 has been noticed to be inconsistent [Wyvern Development, Re, [1974] 1 WLR 1097; Tungsten Electric Co Ltd. v. Tool Metal Manufacturing Co. Ltd., [1955] 1 WLR 761]. Court of Appeal in Baird Textiles Holdings Ltd. v. Marks and Spencer Plc., [2002] 1 All ER (Comm) 737 stated, “there is no real prospect of the claim [estoppel] succeeding unless and until law is developed, or corrected, by House of Lords.”

SCI has given an expansive interpretation to Doctrine of Promissory Estoppel in order to remedy injustice being done to a party who has relied on a promise [Motilal Padampat Sagar Mills Co. Ltd., (1979) 2 SCC 409].

Doctrine of Legitimate Expectation is not merely grounded on analogy with Doctrine of Promissory Estoppel. The need for Doctrine of Legitimate Expectation to have an independent existence was articulated by Justice Frankfurter in Vitarelli v. Seton, 359 US 535 (1959).

– Hon’ble Justice Dr. D.Y. Chandrachud, State of Jharkhand v. Brahmputra Metallics Ltd., [Civil Appeal Nos. 3860-3862 of 2020].