Bojczuk v Gregorcewicz [1961] SASR 128: A Case Law Summary

Bojczuk v Gregorcewicz

In the case of Bojczuk v Gregorcewicz [1961] SASR 128, the court addressed whether a contract entered into by a minor (the defendant) for a loan could be enforced on the grounds of being a “contract for necessaries.”

Key Facts

– The defendant, a minor living in Poland, borrowed money from the plaintiff, her Australian relative, to fund her emigration to Australia.

– Despite agreeing to repay the loan, the defendant failed to do so, prompting the plaintiff to sue for recovery.

– The defendant argued her minority status, claiming that the loan was not enforceable.

Court’s Decision in Bojczuk v Gregorcewicz

The court found in favor of the defendant, holding that the loan was not a contract for necessaries. It reasoned that:

– “Necessaries” under contract law typically include essentials for a minor’s basic needs, such as food, clothing, and shelter—items necessary for survival and well-being.

– The defendant had both employment and accommodation in Poland, which satisfied her needs. Emigrating to Australia was therefore not necessary for her maintenance or livelihood.

– Since the purpose of the loan (emigration to Australia) was not deemed essential to the defendant’s existence, the contract did not meet the threshold of a necessary.

Legal Principle

This case reinforces the principle that for a minor to be liable on a contract, the subject matter of the contract must be essential to their basic needs. Since the defendant’s relocation to Australia did not meet this standard, the contract was unenforceable as a contract for necessaries.

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