On 5 July 2022, the Division Bench of the Delhi High Court held that statements of Delhi’s Chief Minister during a press conference that the National Capital Territory of Delhi shall pay the rent of tenants who are unable to do so owing to poverty when the COVID-19 pandemic comes to an end did not constitute a promise so as to fall foul of the principle of promissory estoppel.
Reading of the transcript of the address reveals that the Chief Minister had beseeched people to stay at home in view of the nationwide lockdown and in that context requested landlords not to evict tenants and also requested the landlords to be empathetic.
The Court observed that a statement given in a consciously held press conference in the background of a lockdown due to the pandemic cannot be overlooked. However, a statement that was merely an assurance is not a part of an election rally, therefore it cannot be considered a political promise.
The Court further explained that the principle of promissory estoppel can only enforce unequivocal, definite and established representations. The pre-requisite for bringing a claim of legitimate expectation is the existence of “clear, unambiguous and devoid of qualification” promise. However, here, the Court found that the statements made did not constitute a promise so as to fall foul of the principle of promissory estoppel.
Reference: High Court of Delhi, Government of NCT of Delhi V. Najma and Ors., (LPA 349/2021).