When is a promise to benefit someone on one's death an enforceable promise? This was the question for the High Court in Gillett v. Holt and Another [1998] 3 All E.R. 917. As Carnwath J. recognised, the difficulty lies in reconciling proprietary estoppel with the principle that “[s]ubject to specific exceptions (such as for dependants), the right to decide, and change one's mind as to, the devolution of one's estate is a basic and well understood feature of English law”.