The High Court has ruled that evidence about the late William Doyle’s intentions may be heard in a dispute over whether his nephew Peter Murphy inherits all the lands on Doyle’s farm or only those at Bealalaw, Myshall.
In a judgment delivered on 1 February 2024, Ms Justice Egan found that the will’s description of the gift was ambiguous. The ruling concerns the first stage of a three-part case: whether extrinsic evidence can be admitted to help interpret the will. It does not determine the final construction of the will or Murphy’s separate proprietary estoppel claim.
Doyle, a 77-year-old bachelor, died on 12 November 2019. His will, made on 19 July 2019, left Murphy “my dwelling house, farm buildings and lands at Belalaw, Myshall” along with entitlements attaching to those lands, farm machinery and livestock. The rest of the estate was left in equal shares to Doyle’s sister and other nieces and nephews.
The estate includes four separate parcels in County Carlow: land at Bealalaw, two parcels at Myshall and a parcel at Raheenleigh. The house and farm buildings are on the Bealalaw lands. Murphy argues that the will gives him all four parcels. The other beneficiaries say the gift covers only the Bealalaw lands, with the remaining parcels passing under the residuary clause. They also plead, in the alternative, that the specific gift is void for uncertainty.
Justice Egan said the wording was more consistent with giving Murphy only the Bealalaw lands, but was not unambiguous. The will did not call the property “my farm” or “farm of lands”, and there was no evidence that the parcels were worked together as one farm. But the phrase “lands at Belalaw, Myshall” could be shorthand either for the land in that townland or for the farm as a whole, described by its address. The will’s opening description of Doyle’s address did not resolve that ambiguity.
The judge therefore ruled that the court would receive extrinsic evidence of Doyle’s intention. She did not rule on whether any particular proposed evidence is admissible. She said her present intention was to hear evidence the parties reasonably wish to tender on a “de bene esse” basis, leaving admissibility for later consideration under the applicable rules.
The judgment records Murphy’s claim that Doyle promised him the farm and that he worked the land expecting to inherit it. That claim remains for a later stage if required. No final decision on the distribution of the disputed lands was made in this ruling.