Brennan J recognised the basis of estoppel by representation as precluding the denial of an existing state of affairs as represented by the party alleged to be estopped, without itself being a cause of action capable of creating new rights. More specifically, Brennan J observed a "logical difficulty" in limiting the enforceability of promises to the context of promissory estoppel and limitations on the promisor's existing rights. An alternative line of estoppel-based reasoning that in substance would have achieved the result the majority had in mind, while providing taxonomical coherence and avoiding the distortion of existing estoppel doctrines, was, nonetheless, open to the court in Waltons Stores. The recognition that different estoppels contain separate requirements and operate in distinct terrains is an important one, for only once the margins and scope of each type have been understood can any rationalisation begin.