Blyth v Estate of Charles Caudle 
The recent decision delivered by the Central County Court in the matter of Charles Caudle’s estate has clearly demonstrated the evidential difficulties an individual is faced with when bringing any type of civil claim and specifically in estoppel claims.
Facts of the case
Charles Caudle and Lucy Blyth met in 2008 a year after his divorce from his ex-wife, Rebecca Muddeman. Ms Blyth moved into Mr Caudle’s multi-million pound house in Dorset and he proposed to Ms Blyth not long after their relationship commenced. However in 2010, Ms Blyth moved out of the house with her three children.
Ms Blyth moved into a bungalow owned by Mr Caudle with her children. Mr Caudle died in 2016 having left a Will, which was executed in 2014, it clearly set out that Mrs Muddeman was the executor and trustee of his estate, with his only child being the beneficiary of the trust. Ms Blyth was referred to as Mr Caudle’s fiancée in his Will but was only provided for to the extent that there was any residue of the estate after specific gifts and legacies were paid out. She was not gifted the bungalow in his Will or by any other means.
Ms Blyth maintained throughout the matter that she was in a subsisting relationship with Mr Caudle at the time of his death and that he had always expressed that she would have “a roof over her head”.
Once the Will was read and it came to light that there wasn’t an express provision for Ms Blyth to remain in the bungalow, the estate commenced action against Ms Blyth for trespass.
Ms Blyth brought her claim against the estate of Mr Caudle on the basis of her being assured that “she would always have a roof over her head” and that there was a letter of wishes which was placed with Mr Caudle’s Will, setting out his intentions.
On the basis that Ms Blyth brought her claim against the estate as an estoppel claim, Ms Blyth would have had to show the following:
- A promise or assurance that she would acquire a proprietary interest in the bungalow;
- That the promise was relied upon by her and on that basis she acted to her detriment; and
- Ms Blyth acted to her detriment in consequence of her reasonable reliance on the promise made by Mr Caudle.
In her mind she believed that there was enough evidence to establish that Mr Caudle had always intended to gift her the bungalow. However, the letter of wishes never materialised and Ms Blyth relied on the equitable remedy to make a claim over the bungalow.
The District Judge delivering judgment, did not believe Ms Blyth was in a relationship with Mr Caudle at the time of his death and furthermore, did not conclude that an individual with great attention to detail would not have taken steps to ensure his wishes were fulfilled.
Ms Blyth lost the case due to what we can only assume was a lack of evidence. Ms Blyth was ordered to vacate the bungalow and pay costs in the sum of approximately £80,000.
Could anything have altered the position in favour of Ms Blyth?
Well yes. If a letter of wishes did exist there would have been clear intention on Mr Caudle’s part to gift the bungalow to Ms Blyth. The evidential burden would have been satisfied in a claim such as this.
Furthermore, had Ms Blyth still been residing with Mr Blyth from the time she moved in and she could show that she was dependant on Mr Caudle, there would have been the potential to bring a claim under the Inheritance (Provision for Family and Dependants) Act 1975.
In summary, these claims live or die on the evidence that is gathered and accordingly it is essential to seek legal advice as early as possible.
How can Nelsons help?
If you have any questions regarding the subjects discussed in this article, please contact Kiren or another member of the team in Derby, Leicester or Nottingham on 0800 024 1976 or via our online form.