Oral agreements: estoppel, constructive trusts and restitution

Analyses the House of Lords judgment in Cobbe v Yeoman's Row Management Ltd in relation to claims by the prospective purchaser under an oral agreement for sale of a block of flats based on proprietary estoppel, a constructive trust and common law restitution brought against the owner of the property who sought to resile from the agreement after the purchaser had, at considerable expense, obtained planning permission to redevelop the property in reliance on assurances given by the owner that if permission was granted the sale would be honoured.

An evaluation of the implementation of hand held health records with adults with learning disabilities: a cluster randomized controlled trial

Background: Personal health records were implemented with adults with learning disabilities (AWLD) to try to improve their health-care. Materials and Method: Forty GP practices were randomized to the Personal Health Profile (PHP) implementation or control group. Two hundred and one AWLD were interviewed at baseline and 163 followed up after 12 months intervention (PHP group). AWLD and carers of AWLD were employed as research interviewers. AWLD were full research participants. Results: Annual consultation rates in the intervention and control groups at baseline were low (2.3 and 2.6 visits respectively). A slightly greater increase occurred over the year in the intervention group 0.6 ()0.4 to 1.6) visits ⁄ year compared with controls. AWLD in PHP group reported more health problems at follow-up 0.9 (0.0 to 1.8). AWLD liked their PHP (92%) but only 63% AWLD and 55% carers reported PHP usage. Carers had high turnover (34%). Conclusions: No significant outcomes were achieved by the intervention.

A regime shift in the North Sea circa 1988 linked to changes in the North Sea horse mackerel fishery

After 1987, Phytoplankton Colour (a visual estimate of chlorophyll) measured on samples taken by the continuous plankton recorder (CPR) in the North Sea increased substantially, both in level and seasonal extent, compared to earlier years since 1946. Many species of phytoplankton and zooplankton showed marked changes in abundance at about the same time. These events coincided with a large increase in catches of the western stock of the horse mackerel (Trachurus trachurus L.) in the northern North Sea reflecting a northerly expansion of the stock along the shelf edge from the Bay of Biscay to the North Sea after 1987. Using a 3D hydrodynamic model, with input from measured wind parameters, monthly transport of oceanic water into the North Sea has been calculated for the period 1976–1994, integrated for a section from Orkney to Shetland to Norway. A substantial increase in oceanic inflow occurred in the winter months, December to March, from 1988. Higher sea surface temperatures were also measured after 1987 especially in spring and summer months. These biological and physical events may be a response to observed changes in pressure distribution over the North Atlantic. From 1988 onwards, the North Atlantic Oscillation (NAO) index, the pressure difference between Iceland and the Azores, increased to the highest positive level observed in this century. Positive NAO anomalies are associated with stronger and more southerly tracks of the westerly winds and higher temperatures in western Europe. These changing wind distributions may have led to an increase in the northerly advection of water along the western edge of the European shelf and may have assisted the migration of the horse mackerel. This study is possibly a unique demonstration of a correlation between three different trophic levels of a marine ecosystem and hydrographic and atmospheric events at decadal and regional scales. The results emphasise the importance of maintaining into the future long term programmes such as the CPR.