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Storer v Manchester City Council [1974] 1 WLR 1403

Contract Law – Offer and Acceptance

Storer v Manchester City Council [1974] 1 WLR 1403 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 refusing to continue with a sale of a residential property to the claimant, Storer. The claimant had agreed with the previous council to purchase the property after receiving a form in the mail. However Storer had left the date of commencement for the sale blank on the application form. Storer had however completed every other term on the document and sent the agreement promptly in the post.

The political party in charge of the constituency at the time was the Conservatives, however they lost the local elections to the Labour party. The council subsequently came under Labour control, who opposed sale of council houses to tenants. As they opposed sale, they refused to continue with the agreement to the claimant.

The claimant stated the contract was completed and sued for the remedy of specific performance of the sale. Manchester City Council argued that conveyance of land in law typically requires both agreements to be signed and exchanged, as such the contract was uncertain.

Issue:

Had the lack of dating prevented the contract from being formed?

Held:

It was determined by Lord Denning that the contract was formed despite missing the term of date. To determine between an offer and invitation to treat it depends on what the words and conduct of the parties objectively and reasonably mean. By sending the letter the council had intended for an offer to be created, which Storer as the claimant subsequently accepted, as such the contract was sucessfully formed.

If the conduct and words of a party seem to indicate intent, then there is intent. Regardless of terms.

This rule has been applied in the following case(s): Gibson v Manchester City Council [1979] 1 WLR 294.

OSCOLA reference this article/case: LawLessons, ‘Storer v Manchester City Council [1974] 1 WLR 1403’ (LawLessons, 31 December 2020) <https://lawlessons.co.uk/storer-v-manchester-city-council-1974-1-wlr-1403> accessed 3rd March 2021

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