The High Court has awarded Michael Coyle €74,000 for work he did on a County Cavan farm, with payment secured by a charge on the farm. The court rejected his claim to inherit the land and farming assets, and awarded no pre-judgment interest.
Coyle sued Matthew Finnegan Junior and Francis Finnegan as personal representatives of Peter Alphonsus O’Reilly, who died in 2007. Coyle claimed O’Reilly had promised in 1991 to leave him the farm, livestock and machinery in return for his help. O’Reilly’s 1991 will left those assets to Coyle, but later wills named the defendants as beneficiaries.
Justice Laffoy found there was no contract requiring O’Reilly to leave the farm to Coyle. Their understanding allowed O’Reilly to change his will, provided he told Coyle. The court therefore refused specific performance of the alleged agreement.
The judge found, however, that Coyle had provided unpaid services between 1991 and 2000 in reliance on O’Reilly’s assurances. The evidence included O’Reilly’s 2003 will, which left Coyle €5,000 for “assistance rendered to me some years ago”. The 2004 will made no provision for Coyle and divided the land between the defendants.
An agricultural consultant assessed Coyle’s labour and other inputs at €74,004.51. The defendants questioned the extent of the work but presented no evidence contradicting the consultant’s assessment. The judge found that €74,000 was reasonable and fair. She also held that the circumstances supported relief under proprietary estoppel, reasoning that it would be unconscionable for the defendants to take the farm without Coyle being recompensed.
The court entered judgment for €74,000 against the defendants as personal representatives of O’Reilly’s estate, with interest at the court rate of 8% from the judgment date, 25 October 2013. It ordered the sum and interest to be charged on the land registered on Folio 173F in County Cavan until paid, and directed the Property Registration Authority to register the charge and Coyle as its owner.