Terms implied by common law and statute

Topic

Terms Implied by Common Law and Statute

In addition to express terms agreed upon by the parties, contracts may also include terms implied by common law or statutory provisions. These implied terms are introduced to ensure fairness, fill gaps, and reflect the presumed intentions of the parties. They are automatically incorporated into contracts unless expressly excluded and can be vital in regulating the contractual relationship, especially in areas not covered by the express terms.

Terms Implied by Common Law

Common law implies certain terms into contracts based on established legal principles, judicial precedents, and the presumed intentions of the parties. Key types of common law implied terms include:

  • Terms Implied in Fact: These are terms that the court considers necessary to give effect to the parties' intentions, often using the "business efficacy" test or the "officious bystander" test. They ensure the contract operates in a practical and functional manner.
  • Terms Implied in Law: These terms are implied into specific types of contracts regardless of the parties' intentions, based on the nature of the relationship and the type of contract. They are intended to protect the interests of the parties and ensure a minimum standard of performance.
  • Customary Terms: These terms are implied based on established customs or practices within a particular trade or locality, provided they are reasonable and consistent with the contract.

Case Law

Business Efficacy - The Moorcock (1889)

In this case, the court implied a term that the wharf owner must ensure the safety of the riverbed for docking ships. The term was implied to give "business efficacy" to the contract, meaning it was necessary to make the contract workable.

Officious Bystander Test - Shirlaw v Southern Foundries (1939)

This case established the "officious bystander" test, where a term may be implied if it is so obvious that it goes without saying. If an officious bystander were to suggest that a certain term should be included, the parties would reply, "Oh, of course!"

Terms Implied by Statute

Statutory provisions often imply terms into contracts to ensure fairness, protect consumers, and regulate specific industries. These statutory implied terms cannot typically be excluded, especially in consumer contracts. Key statutes include:

  • Sale of Goods Act 1979: This Act implies terms into contracts for the sale of goods, such as the goods being of satisfactory quality, fit for purpose, and matching their description.
  • Consumer Rights Act 2015: This Act consolidates and updates consumer rights, implying terms regarding the quality, fitness for purpose, and conformity of goods and services with the contract.
  • Supply of Goods and Services Act 1982: Implies terms that services will be carried out with reasonable care and skill, within a reasonable time, and for a reasonable charge where the price is not determined.

Case Law

Satisfactory Quality - Rogers v Parish (Scarborough) Ltd (1987)

Under the Sale of Goods Act 1979, the court held that a new Range Rover with minor defects was not of satisfactory quality. This case highlighted the statutory implied term that goods must meet the standard that a reasonable person would regard as satisfactory, considering the description and price.

Fitness for Purpose - Grant v Australian Knitting Mills (1936)

This case established that goods must be fit for any particular purpose made known to the seller. The plaintiff suffered a skin reaction due to improperly processed woolen underwear, which was not fit for its purpose, thus breaching the implied term under the Sale of Goods Act.

Examples

Example 1 - Implied Term by Fact

Scenario:

A tenant rents a property from a landlord without an express term regarding the maintenance of common areas. A term may be implied that the landlord is responsible for the upkeep and maintenance of these areas to ensure the property is fit for habitation.

Example 2 - Statutory Implied Term

Scenario:

A customer buys a laptop that stops working within a month due to a manufacturing defect. Under the Consumer Rights Act 2015, a term is implied that the goods must be of satisfactory quality. The customer can return the laptop for a repair, replacement, or refund.

Conclusion

Terms implied by common law and statute play a crucial role in ensuring contracts are fair and effective. They provide a safety net for parties by addressing issues that might not be covered explicitly in the contract. While common law implied terms arise from judicial interpretations and precedents, statutory implied terms are introduced through legislation to protect consumers and standardize contractual obligations. Understanding these implied terms helps parties know their rights and obligations, ensuring better compliance and reducing disputes.

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