Chapelton v Barry Urban District Council [1940]
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Chapelton v Barry Urban District Council [1940] 1 KB 532, also known as the deckchair case, is an English contract law case on offer and acceptance and exclusion clauses. The case stands for the proposition that a display of goods can be a complete offer, not an invitation to treat, and illustrates how onerous exclusion clauses may not be incorporated into a contract.
David Chapelton visited Cold Knap beach with his friend, Miss Andrews, where the Barry Urban District Council provided deckchairs for hire at "2d. per session of 3 hours". A notice near the chairs stated the hire terms, and tickets, containing an exclusion clause exempting the council from liability for accidents or damage, were to be obtained from attendants. Chapelton took two chairs, paid, received tickets, and subsequently suffered an injury when one chair collapsed. The county court judge ruled in favour of the council based on the exclusion clause, but Chapelton appealed.
The Court of Appeal overturned the decision, holding that the display of chairs constituted a valid offer accepted by picking them up. The ticket, seen as a receipt, could not incorporate the exclusion clause as a term since it was issued after the contract was formed. Slesser LJ emphasized that the council's offer was to provide chairs for a fee, with no indication of liability restrictions in the notice. The ticket, a mere voucher, did not alter the contract. MacKinnon LJ and Goddard LJ concurred, emphasising that paying for the chair's use did not imply acceptance of any additional contractual terms.
This case is significant for establishing that a display of goods can constitute a complete offer and that exclusion clauses may not be incorporated if issued after the contract formation. The case clarifies the distinction between contractual terms and receipts or vouchers and highlights the importance of communicating contract terms clearly.
David Chapelton visited Cold Knap beach with his friend, Miss Andrews, where the Barry Urban District Council provided deckchairs for hire at "2d. per session of 3 hours". A notice near the chairs stated the hire terms, and tickets, containing an exclusion clause exempting the council from liability for accidents or damage, were to be obtained from attendants. Chapelton took two chairs, paid, received tickets, and subsequently suffered an injury when one chair collapsed. The county court judge ruled in favour of the council based on the exclusion clause, but Chapelton appealed.
The Court of Appeal overturned the decision, holding that the display of chairs constituted a valid offer accepted by picking them up. The ticket, seen as a receipt, could not incorporate the exclusion clause as a term since it was issued after the contract was formed. Slesser LJ emphasized that the council's offer was to provide chairs for a fee, with no indication of liability restrictions in the notice. The ticket, a mere voucher, did not alter the contract. MacKinnon LJ and Goddard LJ concurred, emphasising that paying for the chair's use did not imply acceptance of any additional contractual terms.
This case is significant for establishing that a display of goods can constitute a complete offer and that exclusion clauses may not be incorporated if issued after the contract formation. The case clarifies the distinction between contractual terms and receipts or vouchers and highlights the importance of communicating contract terms clearly.
