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Gibson v Manchester City Council [1979] 1 WLR 294

Contract Law – Offer and Acceptance

Gibson v Manchester City Council [1979] 1 WLR 294 is a key case within the contract law degree module for UK universities. The case concerns offer and acceptance for the formation of a contract.

Facts:

The defendant Manchester City Council was selling council houses to tenants during the time of the case. The claimant, Gibson, wrote to the council to request details of the residential property he was staying in. The defendant replied to Gibson with a letter stating ‘the council may be prepared to sell the house’, the letter also stated it did not amount to an offer of mortgage but invited the claimant to make an application for the property. A month later, the claimant sent a completed application to the council.

Subsequently, the local political party, who were the Conservatives at the time, lost the seats for the constituency to the rival party Labour. Labour opposed the policy and stated the property would not be sold, unless there was already a legally binding contract in effect. Gibson brought the council to court for breach of contract, the claim suceeded with Lord Denning stating the correspondence should be viewed for intention as a whole and if both parties had come to any kind of agreement citing a ruling from Storer v Manchester City Council [1974].

The council subsequently appealed to the House of Lords.

Issue:

The appeal issue was whether or not the letter sent by the council amounted to an offer, which Gibson accepted.

Held:

Lord Diplock for the House of Lords stated that the letter did not amount to an offer and Gibson’s claim failed. The letter expressly stated intention not to be construed as an offer. Lord Diplock stated to allow exchange of correspondence to amount to a legally enforceable agreement would go against core principles of English Contract Law.

This case uses rulings and decisions found in Storer v Manchester City Council [1974] 1 WLR 1403.

OSCOLA reference this article/case: LawLessons, ‘Gibson v Manchester City Council [1979] 1 WLR 294’ (LawLessons, 31 December 2020) <https://lawlessons.co.uk/gibson-v-manchester-city-council-1979-1-wlr-294> accessed 24th July 2021

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