Principle: Where one of the parties to a contract was in a position to dominate the decision of the other party, the contract is enforceable only at the option of the party who was in a position to dominate decision of the other party.
Facts: A doctor asked his patient to make a payment of Rs. 10,00,000/- (Ten Lac Only) for treatment of his fever. The patient paid an amount of Rs. 5,00,000/- (Five Lac Only) and promised to pay the remaining amount after the treatment. After treatment the patient recovered from fever. The doctor demanded the remaining amount from the patient. The patient refused to pay.

Question

The doctrine of promissory estoppel is by now well recognized and well defined by a catena of decisions of this Court. Where the Government makes a promise knowing or intending that it would be acted on by the promise and, in fact, the promise, acting in reliance on it, alters his position, the Government would be held bound by the promise and the promise would be enforceable against the Government at the instance of the promise notwithstanding that there is no consideration for the promise and the promise is not recorded in the form of a formal contract as required by Article 229 of the Constitution. The rule of promissory estoppel being an equitable doctrine has to be moulded to suit the particular situation. It is not a hard-and-fast rule but an elastic one, the objective of which is to do justice between the parties and to extend an equitable treatment to them. This doctrine is a principle evolved by equity, to avoid injustice and though commonly named promissory estoppel, it is neither in the realm of contract nor in the realm of estoppel. For application of the doctrine of promissory estoppel the promise must establish that he suffered in detriment or altered his position by reliance on the promise.
Normally, the doctrine of promissory estoppel is being applied against the Government and defence based on executive necessity would not be accepted by the court. However, if it can be shown by the Government that having regard to the facts as they have subsequently transpired, it would be inequitable to hold the Government to the promise made by it, the court would not raise an equity in favour of the promise and enforce the promise against the Government. Where public interest warrants, the principles of promissory estoppel cannot be invoked. The Government can change the policy in public interest. However, it is well settled that taking cue from this doctrine, the authority cannot be compelled to do something which is not allowed by law or prohibited by law. There is no promissory estoppel against the settled proposition of law. Doctrine of promissory estoppel cannot be invoked for enforcement of a promise made contrary to law, because none can be compelled to act against the statute. Thus, the Government or public authority cannot be compelled to make a provision which is contrary to law.
[Extract from the judgment of the Supreme Court in Shree Sidhbali Steels Limited v. State of Uttar Pradesh, (2011) 3 SCC 193, decided on January 20, 2011, hereafter ‘Shree Sidhbali Steels’].

Answer 1

The first step is spotting who was in the position to dominate the other's decision, since the principle only gives that party the enforcement option.

Enforceable against the doctor: Wrong, the doctor was the one in the dominant position over the patient, not the reverse.
Enforceable against the patient: The doctor, being dominant, has the option to enforce the promise for payment, and demanded it, so the contract binds the patient.
Not enforceable: Incorrect, the principle keeps the contract alive through the dominant party's choice rather than voiding it entirely.
Not enforceable against the patient: This contradicts the outcome of the doctor exercising his option to enforce.

The correct answer is The contract is enforceable against the patient.

Answer 2

Testing each option by assumption.

Enforceable against the doctor: Assume true, then the patient would have to be the dominant party over the doctor. Nothing in a patient urgently seeking treatment for a fever suggests he dominated the doctor's decisions, so this assumption has no footing in the facts.
Enforceable against the patient: Assume true, then the doctor must be dominant and must have chosen to enforce. Both hold, the doctor occupies the position of professional authority over a patient in need of treatment, and the doctor did demand the outstanding amount, confirming the choice to enforce. The assumption survives.
Not enforceable: Assume true, then the principle would have to void such contracts entirely rather than leave enforcement to the dominant party's discretion. But the rule specifically preserves an enforcement route through that party's option, so declaring blanket unenforceability contradicts the principle's own structure.
Not enforceable against the patient: Assume true, then the dominant party's demand for payment would have to be legally meaningless. Since the doctor, as the dominant party, is the one the principle empowers to enforce, and he did demand payment, this assumption runs against the facts.

Only the assumption that the contract binds the patient survives, since the doctor was dominant and exercised his option to enforce.

Therefore, the correct answer is The contract is enforceable against the patient.

Answer 3

Testing each option by assumption.

Enforceable against the doctor: Assume true, then the patient would have to be the dominant party over the doctor. Nothing in a patient urgently seeking treatment for a fever suggests he dominated the doctor's decisions, so this assumption has no footing in the facts.
Enforceable against the patient: Assume true, then the doctor must be dominant and must have chosen to enforce. Both hold, the doctor occupies the position of professional authority over a patient in need of treatment, and the doctor did demand the outstanding amount, confirming the choice to enforce. The assumption survives.
Not enforceable: Assume true, then the principle would have to void such contracts entirely rather than leave enforcement to the dominant party's discretion. But the rule specifically preserves an enforcement route through that party's option, so declaring blanket unenforceability contradicts the principle's own structure.
Not enforceable against the patient: Assume true, then the dominant party's demand for payment would have to be legally meaningless. Since the doctor, as the dominant party, is the one the principle empowers to enforce, and he did demand payment, this assumption runs against the facts.

Only the assumption that the contract binds the patient survives, since the doctor was dominant and exercised his option to enforce.

Therefore, the correct answer is The contract is enforceable against the patient.

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The Correct Option is B

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