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FORMING A CONTRACT – MUTUAL ASSENT

Dictum

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)

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SUCCEEDING IN A BREACH OF CONTRACT

For a claimant to succeed in an action for breach of contract, he must establish not only that there was a breach but also that there was in existence an enforceable contract which was breached.

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

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COURT DOES NOT CONDUCT BARGAIN FOR PARTIES

The appellant having failed to name a price for his ‘injury’ as a solatium, he cannot expect from the court, unsolicited, any succour as the business of this court or of any court for that matter does not include conducting bargain on behalf of any party.

– Olagunju JCA. Ofodile v. COP (2000)

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WHEN TERMS OF CONTRACT ARE CLEAR, INTERPRETATION IS NEGLIGIBLE

In the construction of a contract, the meaning to be placed on it is that which is the plain, clear and obvious result of the terms used. A contract or document is to be construed in its ordinary meaning, When the language of a contract is not only plain but admits of one meaning, the task of interpretation is negligible. See: Union Bank of Nig. Ltd & Anr Vs Nwaokolo (1995) 6 NWLR (Pt. 400) 127: Aouad & Anor Vs Kessrawani (1956) 1 FSC 35: Nwanowu Vs Nzekwu & Anor (19571 3 FSC 36: Orient Bank (Nig) Plc Vs Bilante Int. Ltd (19971 8 NWLR (Pt. 515) 37 @ 78 B-D.

— K.M.O. Kekere-Ekun JSC. B.O. Lewis v. United Bank for Africa Plc. (SC.143/2006, 14 January 2016)

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PARTIES ARE BOUND BY AGREEMENT ENTERED INTO

Parties are bound by the terms of the agreement they have voluntarily entered into. The only function of the court is to interprete the agreement in enforceable terms without more.
[Kurubo v. Zach-Motison (Nig.) Ltd (1992) 5 NWLR (Pt. 239) 102; National Salt Co. (Nig.) Ltd v. Innis -Palnier (1992) 1 NWLR (Pt. 218) 422; Union Batik of Nigeria Ltd. v. Ozigi (1994) 3 NWLR (Pt. 333) 385; Shettiniari v. Nwokoye (1991) 9 NWLR (Pt. 213) 60]. – L.A. Ayanlere v. Federal Mortgage Bank of Nig. Ltd. (1998) – CA/K/186/96

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TERMINATION OF CONTRACT OF SERVICE BRINGS TO AN END MASTER-SERVANT RELATIONSHIP

Chukuma v. Shell Petroleum Development Company (1993) 4 NWLR (Pt. 289) 512 at 560 where Karibi-Whyte JSC said: “In the ordinary case and following the common law principle,termination of a contract of service even if unlawful brings to an end the relationship of master and servant, employer and employee. This rule is based on the principle of the confidential relationship between master and servant which cannot continue in the absence of mutuality.”

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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

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