Judiciary-Poetry-Logo
JPoetry

AWARD OF DAMAGES FOLLOWS BREACH OF CONTRACT

Dictum

An award of damages usually follows a breach of contract so as to compensate the injured party for loss following naturally and within the contemplation of the parties. Damages is attached to a breach following an enforceable contract. Where there was no such contract an award of damages by any Court is not only a misconception but a contradiction in terms as such award is based on a wrong principle of law. This court has a duty not to allow such an award to stand.

— Adekeye, JSC. Best Ltd. v. Blackwood Hodge (2011) – SC

Was this dictum helpful?

SHARE ON

OFFER & A COUNTEROFFER

An offer must be unconditionally and unqualified by accepted. Any addition to or subtraction from the terms of the offer is an alteration to the terms and amounts to a total rejection of the offer by the offeree. The terms embedded in the rejection may form the basis for the formation of a new agreement. This is what amounts to a counter-offer. An offer is impliedly rejected if the offeree instead of accepting the original offer makes a counter-offer which varies the terms proposed by the offeror. Hyde v. Wrench (1840) 3 Kear. 334.

— Adekeye, JSC. Best Ltd. v. Blackwood Hodge (2011) – SC

Was this dictum helpful?

FORMING A CONTRACT – MUTUAL ASSENT

The nature of the plaintiffs/appellants’ claim, as averred in their amended Statement of Claim, which of course they failed to prove, was that there was a subsisting contract between the parties. Whether or not there is a semblance of a legally binding agreement between the parties, that is, a situation where the parties to the contract confer rights and impose liabilities on themselves, will largely depend on whether there exists a mutual assent between them. Where there is doubt on whether the parties have concluded a legally binding agreement, the court has the responsibility to analyse the circumstances surrounding the alleged agreement and determine whether the traditional notion of ‘offer’ and “acceptance” can be distilled from the purported agreement. The mutual assent must be outwardly manifested. The test of the existence of such mutuality is objective. See Norwich Union Fire Insurance Society v Price (1943) AC 455 at 463. When there is mutual assent, the parties are said to be ad idem. Now the two items, “offer” and “acceptance”, earlier referred to, call for some explanation in order to recognise whether or not the parties are ad idem. An ‘offer’ is an expression of readiness to contract on the terms specified by the offeror (i.e. the person making the offer) which if accepted by the offeree (i.e. the person to whom the offer is made) will give rise to a binding contract. In other words, it is by acceptance that the offer is converted into a contract.

— Achike, JSC. Sparkling Breweries v Union Bank (SC 113/1996, 13 July 2001)

Was this dictum helpful?

COURT CANNOT IMPOSE CONTRACT ON A PARTIES

The relationship between the parties in this case is well-scripted, known and appreciated by them. The Court cannot write or rewrite any agreement for the parties. The parties to any transaction usually have their positions which they bring to their table of negotiation. When they are done with their negotiations, they now have their terms well-crafted to govern the transaction they enter into. The parties and no other are responsible for their terms of engagement. No Court has the power to script or foist on the parties terms which are strange to their agreement. Parties are bound by the terms of their contract.

— S.J. Adah, JCA. Luck Guard v. Adariku (2022) – CA/A/1061/2020

Was this dictum helpful?

WRONGFULLY TERMINATED CONTRACT

Where an employee’s appointment is wrongfully terminated, his remedy lies in an action for damages, because the court cannot force an employer to keep an employee in his services if the employee’s services are no longer required. The normal measure of damages the employee would be entitled to, is what he would have earned over the period of notice required to lawfully terminate his employment. This is consistent with the contract between the parties which has stipulated the measure of damages. See: Onalaja v. African Petroleum Ltd. (1991) 7 NWLR (Pt. 206) 691 ; Taiwo v. Kingsway Stores Ltd. (1950) 19 NLR 122 and Union Bank of Nigeria Ltd. v. Ogboh (1995) 2 NWLR (Pt. 380) 647.

– Muhammad JCA. Osumah v. EBS (2004)

Was this dictum helpful?

SETTING ASIDE A VOIDABLE CONTRACT IS NOT AUTOMATIC

As I observed a moment ago, the setting aside of a voidable transaction cannot be automatic. If it were, there will then be no difference between a void transaction (whose setting aside is automatic) and a merely voidable transaction (whose setting aside depends on all the equities and surrounding circumstances).

– Oputa, JSC. Adejumo v. Ayantegbe (1989)

Was this dictum helpful?

WHEN AGREEMENT IS MADE

An agreement is made where there exists an offer, acceptance, consideration, capacity to contract and intention to create legal relationship. – Niki Tobi JSC. Yaro v. Arewa CL (2007)

Was this dictum helpful?

No more related dictum to show.