What happened in Roberts v Gray?
In Roberts v Gray [1913] 1 KB 520, the case involved a contract between a minor, who was an aspiring billiards player, and an experienced professional player. The minor agreed to accompany the professional on a world tour, which would serve as an opportunity to gain valuable experience and further his career. As part of the agreement, the professional player, the plaintiff, made arrangements for the minor’s lodging and travel and expended a lot of time to make the preparations.
However, before the tour commenced, a dispute arose between the minor and the professional player, leading the minor to withdraw from the agreement. The minor claimed that, as a minor, he was not bound by the contract and argued that it was unenforceable.
Decision of the Court
The court held that the contract was enforceable despite the minor’s age, reasoning that it was a “beneficial contract of service.” In other words, contracts that provide employment, education, or training, and are primarily for the minor’s benefit, can be binding on the minor. In this case, the court viewed that the experience the minor would have gained would have been advantageous for his career. Consequently, the court awarded damages to the plaintiff as compensation for the minor’s breach of contract.
Principle
This case illustrates that while minors generally lack the capacity to enter enforceable contracts, exceptions exist for contracts deemed beneficial to the minor, especially those related to employment, education, or training.
References:
- https://www.hzu.edu.in/uploads/2020/10/97-contract-law-willan-publishing-2007.pdf
- https://www.serbest.av.tr/dosyalar/dosya_14394_Capacity.pdf
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