"promissory estoppel". Contractual / legal relationship It remains unsettled whether promissory estoppel may arise in pre-contractual relationships. In the case Brikom Investments Ltd v Carr, a landlord made an oral promise to his tenants that if they bought a 99-year lease to their flats he would repair the roofs of the flats at his own expense. After the leases had been signed by the tenants, the landlord repaired the roof at a cost of £15,000. The landlord then claimed a contribution from the tenants towards the cost of the repairs. The tenants refused to pay because of the promise made. The landlord claimed that Carr could not rely on her promise since she had not acted on his promise because she would have entered into the lease without any such promise having been made. However, Lord Denning was of the view that promissory estoppel may arise from promise made by parties negotiating contracts. Similar views was expressed in Durham Fancy Goods v Michael Jackson, where Donaldson J held that contractual relationship is irrelevant provided that there is “a pre-existing legal relationship which could, in certain circumstances, give rise to liabilities and penalties”. Detrimental reliance on the representation The proof of possible detriment or prejudice, which will appear if the promisor is allowed to revert to his original promise, is required. In Ajayi v Briscoe the Privy Council ruled that there was no estoppel where the promisee alters his position as a result of relying on the promise yet suffers no overall detriment. In Alan Co. Ltd v El Nasr & Import Co., Denning detained that detriment is not an essential element of promissory estoppel. Therefore, for a plea of promissory estoppel to succeed, there must be a change in circumstances of the promisee. This elementary composition of promissory estoppel has been the core and central topic of discussion in the evolution of the doctrine. Temporary suspension of contractual obligations and rights This doctrine does not operate to completely extinguish the original rights of the parties accruing from the contract. It only provides for the suspension of such right, which can subsequently be revived after a certain event or time. In Tool Metal Manufacturing v Tungsten, The courts held that generally promissory estoppel will merely suspend legal rights rather than extinguish them. However, where periodic payments are involved and a promise has been made to reduce the payments because of pressing