11. Promissory estoppel relates to a form of future conduct. 12. The doctrine of promissory estoppel may not make the total contract fully enforceable. 13. It remains unsettled whether promissory estoppel may arise in pre-contractual relationships. 14. Additionally, unconscionability is a necessary element to the finding of proprietary estoppel . 15. Here, promissory estoppel created the cause of action where there was none. 16. But there are differences between a contract and an equity created by estoppel . 17. Promissory estoppel or unjust enrichment may be available, but generally are not. 18. This rationale is comparable to the doctrine of legal estoppel under US law. 19. There remains the so-called question of estoppel . 20. Third, people can acquire land through proprietary estoppel .
