Lens v Devonshire Club (1914) The Times, 4 December
Facts (Lens v Devonshire Club)
The case Lens v Devonshire Club (1914) illustrates a key principle in contract law regarding the intention to create legal relations, particularly in social contexts. In this case, the winner of a local golf competition was unable to claim a prize, as the court ruled that there was no intention to create legal relations between the parties.
Court’s decision
The court highlighted that in social or recreational situations, there is usually a presumption against the intention to create legal consequences.
The conditions posted by the club and accepted by the competitor were seen as informal or non-binding, reflecting a lack of intent to form a legally enforceable contract. The ruling emphasized that “…no one concerned with that competition ever intended that there should be any legal results flowing from the conditions posted and the acceptance by the competitor of these conditions…”.
However, the presumption against legal intent can be rebutted if a claimant can demonstrate that they relied on the agreement in a way that indicates an intention to create legal relations. If the evidence shows that both parties intended for the transaction to have legal consequences, the court may enforce the contract based on the circumstances of each case.
References:
- https://www.serbest.av.tr/dosyalar/dosya_13634_Intention-to-Create-Legal-Relations.pdf
- https://fdvn.vn/wp-content/uploads/2019/12/luu-ban-nhap-tu-dong-3-1.pdf
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