‘Expectation, or trust, is not enough’ to establish mutual wills – what is required ‘is a clear agreement, whether strictly contractual or not’ – and while the argument that some form of estoppel would be sufficient to establish mutual wills ‘has a significant degree of plausibility’, ‘facts which are fatal to establishing mutual wills by agreement are equally fatal to the estoppel argument’: https://caselaw.nationalarchives.gov.uk/ewhc/ch/2023/1863
