Parker v Clark (1960) 1 WLR 286 is an English contract law case that deals with the concept of reliance and the creation of legal relations in a social or familial agreement. The case involved a dispute between the Clarks, an elderly couple, and their niece and her husband, the Parkers, who were invited to live with the Clarks under certain assurances.
The Clarks invited their niece and her husband, the Parkers, to live with them. The Parkers expressed their willingness to accept the invitation but mentioned that it would require them to sell their own house. In response, the Clarks assured the Parkers that, if they sold their house and moved in, they would leave a share of the Clark house to Mrs Parker and her daughter in their will. Relying on these assurances, the Parkers sold their house and lent the money to the Clarks' daughter, who used it to purchase a flat. The Parkers then moved in with the Clarks. However, a dispute arose between the parties, leading to the Clarks asking the Parkers to leave, which resulted in the Parkers suing for breach of contract.
The court held that the Clarks were liable for damages to the Parkers. The judge reasoned that the Clarks had made an assurance to the Parkers that they would have a place to stay, and the Parkers had relied on this assurance to their detriment. The judge expressed disbelief that the Clarks genuinely thought that they could, at their discretion, change their minds and tell the Parkers to leave without providing them with alternative accommodation or considering their well-being. The judge's decision was based on the principle that the Clarks, through their assurances, had created a legal relationship and that the Parkers had reasonably relied on those assurances to their detriment by selling their house and lending the money. As a result, the Clarks were found liable for damages due to their breach of the assurances provided to the Parkers.
Parker v Clark highlights the significance of reliance and the creation of legal relations, even in social or familial agreements. In this case, the Clarks' assurances to the Parkers were considered binding, and the Parkers' reliance on those assurances led to the court finding the Clarks liable for damages when they breached their agreement. This case illustrates that contractual principles can extend to family and social arrangements when parties rely on promises to their detriment.
You can learn more about this topic with our Contract Law and Property Law notes.
