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Barton v Armstrong [1976] AC 104

Contract Law – Duress

Barton v Armstrong [1976] AC 104 is a key case within the contract law degree module for university LLB degree courses. The case concerns the effects of duress on a contract.


In this case, both Barton and Armstrong were the majority shareholders of Landmark Corporation Ltd. Barton was the managing director amongst two other directors. It is reported that historical aggression existed inside the company as to who should have the controlling stake. Other directors were unhappy with Armstrong stating he abused power and created a risk of insolvency.

The directors called for Armstrong to resign but he refused, this lead to the three others to steadily take control of subsidiaries and facilities. Armstrong discovered this and coerced Barton into buying his shares above market value via the use of death threats. Barton stated he agreed partly due to the threats but also so he could remove Armstrong’s controlling interest in the company.


Did Barton sign due to duress or an ancillary motive to remove Armstrong for the benefit of Landmark Corporation?


The contractual agreement was void due to duress as found during an appeal. Regardless of any ancillary motive, if duress has occurred at any stage of an agreement, it can be considered voidable.

OSCOLA reference this article/case: Lawlessons, ‘Barton v Armstrong [1976] AC 104 ‘ (LawLessons, 11th August 2021) <> accessed 8th July 2022

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