Fry v Lane [1888]

Fry v Lane [1888] 40 ChD 312 is a significant English contract law case that deals with the exploitation of weakness, providing an avenue to escape from a contract. The central issue in this case is the alleged exploitation of two individuals, JB and George Fry, who, despite their modest income, sold the reversion of their Uncle's estate.

JB and George Fry, employed as a plumber and laundryman respectively, earned a weekly income of £1. Despite their limited financial means, they held the reversion of their Uncle's estate, which was subject to the life tenancy of their Aunt. In 1878, they sold the reversion to Mr Lane for £170 and £270. The solicitor advising them was inexperienced and also acted for Mr Lane. Subsequently, when the Aunt passed away in 1886, the value of their interests had significantly increased to £730 each, whereas in 1878, it would have been £475.

Kay J, in delivering the judgment, highlighted that equity commonly intervenes in favour of individuals who are expectant heirs, especially those in their youth or individuals with modest means and limited education. In such cases, the onus is on the purchaser to demonstrate that the transaction was fair, just, and reasonable.

Kay J emphasised that the undervalue in this case was so gross as to amount of itself to evidence of fraud. The judgment reflects the court's willingness to intervene when vulnerable parties, such as those with limited financial resources and education, are taken advantage of in contractual transactions. The case stands as an illustration of the court's commitment to ensuring fairness and justice in contracts involving individuals in precarious situations.
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