Contract Law Assignment

Abstract

This assignment examines the law of contract in general and provides the opportunity to study the law of contract from a minors perspective. This includes the study of offer, acceptance, voidable contracts and consideration, and their relevance to contracts that minors are party to, and breach of contracts and remedies available to each contracting party. It analyses the need to draw a balance between

protecting the minor against his inexperience and protecting the contracting adult who has acted in good faith. This is achieved by looking at the enforceability of goods and services contracts that minors are party to. In general, contracts entered by a minor are not binding, unless he ratifies them on reaching majority although there are exceptions and qualifications to these rules, namely that contracts to provide necessary goods and services and contracts of service for the minors benefit are enforceable. The assignment also examines the minors liability for bank loans and any remedies that may be available to the lender.

This is carried out by looking at: legislation, including the Minors Contract Act 1987 which was enacted to improve the rights of an adult who makes a voidable contract with a minor; case law, and academic opinion in legal journals which argues that the law relating to minors and contracts can be unclear at times. The assignment then concludes on the issue that the rules relating to necessaries can trap those acting in good faith and a better balance is needed between protecting the minor and the interests of those of the other party, to the extent that the courts are now more concerned with producing justice in individual cases rather than laying down general rules.

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Question Minor Upset, who is 17 and lives in an isolated rural village, has recently been offered a job as a software engineer in the nearest town which is twenty miles from the village. As there is no bus or train service, he agreed to buy a second hand car from Plusitup Motors Ltd for 3,000 having successfully negotiated a bank loan for 5,000 from the Recession Bank Ltd. Two days later on discovering that he would be able to get a lift to and from work from a neighbour, he informed Plusitup Motors Ltd that he no longer needed the car and would neither collect it nor pay for it.

He also purchased a personal stereo system and a set of golf clubs from General Trading Plc., a large retail store in the nearest town. He has paid for the stereo system but not for the golf clubs. He is now claiming that due to a fault in the stereo, an irreplaceable tape of great sentimental value has been destroyed.

Minor Upset has now realised that his financial calculations were wrong and he will be unable to re-pay the bank loan, upon so informing the bank, Minor Upset has been threatened with court proceedings.

Advise all the above parties as to their legal positions in respect of the above transactions in the law of contract.

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12th November 2010 Our Ref: CL1211/10 Re: Contracts

Dear Minor Upset Further to your recent consultation at this office we are writing to inform you of your legal position and that of the other contracting parties. There is no need at this point to go into detail about the formation of a contract as you are a minor1 and this fact will have an impact on the enforceability and outcome of each contract.

In general, contracts entered by a minor are not binding, unless he ratifies them on reaching majority.2 There are currently exceptions to the rule, and consequently contracts to provide necessary goods and services and contracts of service for the minors benefit3 are enforceable. The rationale of the law4 is to protect minors against their liability in cases of contract5as it is obviously unfair to treat all minors like adults in contract law. On the other hand a balance must be reached as there can be unfair consequences for the adult who has contracted in good faith6 with the minor. Legislation now addresses both these issues through two general principles: the law must protect the minor against his inexperience7 and the law should not cause unnecessary hardship to adults who deal fairly with minors. 8 The Minors

Family Law Reform Act 1969 s1, and people age 18 and under are also referred to as minors in Sale of Goods Act 1979 s 3 and Minors Contract Act 1987 and Minors Contracts (NI) Order 1988 2 Chen-Wishart, W. Contract Law (3rd ed. Oxford University Press, Oxford, 2008) at W1.1 3 Elliott, C & Quinn, F Contract Law (7th ed. Harlow: Longman, 2009) at 70 4 Stone, R and Cunnington, R Text, Cases and Materials on Contract Law (Routledge-Cavendish, Oxon, 2007) at 322 5 Jennings v Rundall (1799) 101 E.R. 1419 Lord Kenyon at 1421 6 th McKendrick, E Contract Law (7 ed. Palgrave Macmillan, 2007) at 348 7 th Peel, E Treitel The Law of Contract (12 ed. Sweet & Maxwell, London, 2007) at 567 8 Ibid at 567

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Contracts Act 1987 was introduced to improve the rights of an adult who makes a voidable contract with a minor9 if it is just and equitable to do so10 wherein the seller now has a limited measure of redress11.

Minors are not bound by contracts into which they enter12 with the exception of necessaries and contract of employment for his benefit but he can be held liable in a number of ways which we will examine in due course. Before 198713 all contracts for goods supplied were absolutely void, the only exception being contracts for necessaries.14 (Necessaries being articles fit to maintain the particular person in the state, station and degree in life in which he is;15 the only way that a minor can be bound by a contract is if the goods are necessaries as quoted in both Burnard 16 case and Ryder17 case.) Prior to the 1874 Act at common law, irrespective of statute, the contracts of an infant were voidable except such as were necessarily to his prejudice; these last were void.18 The 1874 Act led to sanction a cruel injustice.19 The common law is now in place again as the act has been repealed by the Minors Contracts Act 1987.

Contract Law and Minors (1993) Cons. L. Today 16 (10) Supp IF iii-iv at iii Minors Contracts Act (1987) s3 (Minors Contracts (NI) Order 1988 is NI equivalent) 11 th Brownsword, R Smith & Thomas: A Casebook on Contract (12 ed Sweet & Maxwell, 2009) at 735 12 th McKendrick, E Contract Law (7 ed. Palgrave Macmillan, 2007) at 349 13 Before Minors Contracts Act 1987 14 Nash v Inman (1908) 2 KB 1 Cozens-Hardy MR at 5 15 Peters v Fleming 151 E.R. 314 Parker B at 316 16 Burnard v Haggis 143 E.R. 360 at 364 17 Ryder v Wombwell (1868-69) L.R. 4 Ex. 32 Willes J at 38 18 Nash v Inman (1908) 2 KB 1 Buckley LJ at 11/12 19 Valentini v Canali (1) [1890] LR 24 QBD 166 Lord Coleridge CJ at 167
10

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The laws strongly protective attitude towards children20 fraudulent child can only be made to give back what is left.21

meaning that even a

This will be considered as we now deal with your liability in each contract separately.

20 21

Chen-Wishart, W. Contract Law (3rd ed. Oxford University Press, Oxford, 2008) Online at W7 Ibid at W7

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Issue 1: Contract with Plusitup Motors Ltd

In the case of the car as a minor you are liable for goods sold and delivered to you22. Before the enactment of Sale of Goods Act 1979, it was unclear whether the goods must be necessary at the time of sale as well as at the time of delivery.23 In fact it was recognised that there were no cases in which an infant has been held liable for the purchase of goods being necessaries when the goods have not been sold and delivered.24 This is supported by the view that goods must be necessary when delivered.25 The car was a necessary when you agreed to buy it as there was no public transport to take you to your work, and similar cases can be applied, for example, the hire of a car to fetch luggage from a station six miles away 26 and a racing bicycle27 were both held to be necessaries. It would no longer be a

necessary at the time of delivery as you made alternative travel arrangements to work, therefore if s3 (3) of Sale of Goods Act28 is applied, the car is not a necessary and consequently you are not bound by the contract. This argument is supported in both common law29 and legislation.30

Another aspect you may consider is that as you have decided to not buy the car after agreeing with Plusitup Motors Ltd it must be considered whether you are in the

22 23

Sale of Goods Act s3 (2) Chitty on Contract General Principles Volume 1 at 676 24 Miles, JC The Infants Liability for Necessaries (1927) 43 LQR 389 at 389 25 Winfield (1942) 58 LQR 82 in which Winfield discusses necessaries under the Sale of Goods Act 1893 26 Chitty on Contract General Principles Volume 1 at 678 referring to Fawcett v Smethurst (1914) 1 SALK 279 27 Ibid at 676 referring to Clyde Cycle Co v Hargreaves (1898) 78 LT 296 28 Sale of Goods Act 1979 s3 (3) necessaries mean goods suitable ...to his actual requirements at the time of the sale and delivery 29 Nash v Inman (1908) 2 KB 1 Fletcher Moulton LJ held the minor was liable because he had been supplied and not because he had been contracted. 30 Sale of Goods Act 1979 s3 (2) Where necessaries are sold and delivered [to a minor]... he must pay a reasonable price for them.

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position to revoke your agreement. The principle in Payne v Cave31 is that an offer may be withdrawn at any time up until it is accepted32 but as the agreement was already formed this is not applicable. Another consideration is that if the contract lacks certainty it is incomplete33 this could be applied to your case if no date was set for completion of the contract with the car,34 uncertainty arises around the price for the goods.35 although in most cases the

Section 3(1) of Minors Contracts Act 1987 provides... means of ordering children to make restitution36 where the contract is not binding. Accordingly, the court may, if it is just and equitable to do so, order you to transfer to the seller any property acquired by you under the contract or any property representing it.37

Issue 2: Contract with Recession Bank Ltd You borrowed money to buy a car which was a necessary at the time of agreement. This leads on to the next issue your contract with Recession Bank Ltd. As a minor you are not liable for any loans38, as the contract is therefore unenforceable, a remedy may be available to the bank. If the money was fraudulently obtained by a minor39 he could be held not to be liable in equity (the only remedy available) to repay it if the money cannot be traced. If it can be traced or if the money is still in his

31 32

Payne v Cave (1789) 3 Term Rep 148 Elliott, C & Quinn, F Contract Law (7th ed. Harlow: Longman, 2009) at 19 33 th Peel, E Treitel The Law of Contract (12 ed. Sweet & Maxwell, London, 2007at 54 34 Harvey v Pratt (1965) 1 WLR 1025 also applies in Scammel v Nephew Ltd v Ouston (1941) AC 251 and May Butcher v R (1934) 2 KB 17n 35 Scammel v Nephew Ltd v Ouston (1941) AC 251 and May Butcher v R (1934) 2 KB 17n 36 Chen-Wishart, W. Contract Law (3rd ed. Oxford University Press, Oxford, 2008) at W8 37 Minors Contracts Act 1987 s 3 (1) 38 Halsburys Laws of England 21 Loans to provide necessaries 39 R Leslie Limited v Sheill [1914] 3 K.B. 607

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possession he would be liable to return it.40 This decision was made in the Sheill case and was almost universally vilified.41 In your case the loan was not

fraudulently obtained therefore a remedy in equity is not applicable.

Liability in restitution at common law is expressly reserved by s3(2) of Minors Contracts Act 1987.42 You could be ordered to hand over the property bought with the money under s3 (1) of 1987 act. This could result in an order to transfer... property even in the absence of fraud43although you will not be obliged to use your own assets that are separate to the goods or money. If you have spent all the money received in a contract, under s3(1) of the 1987 Act the court cannot make an order, but if there is an amount left you can be ordered to transfer the remainder.44 Now it is open to a creditor to induce a former minor to repay a previously unenforceable loan, after majority.45 You are not liable for the loan either if, contrary to s50 of Consumer Credit Act 1974 the bank canvassed you for the loan,46 but we would need to know whether this is the case before pursuing this issue.

In common law if the bank lends you money to pay for necessaries, it can only recover the amount of the loan that was used to purchase necessaries, and only if you still have them.47 This case is still applicable to day as it is the common law reverted to since the enactment of the Minors Contracts Act 1987

40

Peel, E Treitel The Law of Contract (12 ed. Sweet & Maxwell, London, 2007) at 584 41 Clarke, RW Contracts for the Sale of Non-Necessary Goods; Vendors Remedies Against an Infant Purchaser (1981-1983) 7 U. Tas. L. Rev. 85 at 93 42 th Peel, E Treitel The Law of Contract (12 ed. Sweet & Maxwell, London, 2007) at 585 43 Ibid at 584 44 th Treitel, GH An Outline of the Law of Contract (6 ed. Oxford University Press, Oxford, 2004) at 232 45 Holroyd, J Young People The Minors Contracts Act 1987 LS Gaz 29 Jul 84 (2266) 46 Contract Law and Minors (1993) Cons L Today 16910) Supp IF iii-iv 47 Marlow v Pitfeild (17119) 2 Eq Ca Ab316 pl6

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Issue 3: Contract with General Trading Plc By accepting your offer48 to purchase the golf clubs and personal stereo, the seller was assenting to all the terms of the offer.49 Any agreement needs to be supported by consideration50 as a person must show that he or she has bought the...

promise51. You have provided executed consideration for the personal stereo as you paid for it at the time of offer and acceptance, therefore it is valid consideration. In the case of the golf clubs there is executor consideration as you have not yet paid for them, although you had intended to do so at the time of offer and acceptance. This is also valid consideration. Steyn questions why the law will not sanction a contract if there is no consideration even though the parties seriously intend to enter legal relations,52 and Lord Denning has also questioned whether consideration is an important part of the contract formation.53 Despite this consideration is a necessary component of the formation of a contract. It is a commercial agreement 54 therefore there will be a presumption that you intended to create legal relations with the seller which, again is required to form a contract.

As a minor you can only be bound in a contract for the supply of necessary goods and services.55 The golf clubs and personal stereo are not necessaries, as they are neither food, drink, clothing, lodging and medicine56 nor goods for real use57, and
48 49

Pharmaceutical Society of Great Britain v Boots (1953) 1 QB 401 and Fisher v Bell (1961) 1 QB 394 Elliott, C & Quinn, F Contract Law (7th ed. Harlow: Longman, 2009) at 12 50 th Treitel, GH An Outline of the Law of Contract (5 ed. Butterworths, London, 1995) 51 Elliott, C & Quinn, F Contract Law (7th ed. Harlow: Longman, 2009) at 9 referring to Dunlop Pneumatic Tyre Company v Selfridge (1915) AC 847 52 Steyn, J Contract Law: Fulfilling the Reasonable Expectations of Honest Men (1997) 113 LQR 433 at 437 53 Lord Denning Recent Developments in the Doctrine of Consideration (1952) 15 MLR 1 The law for centuries has been that an act done, at the request of another, express or implied, is sufficient consideration to support a promise. 54 th McKendrick, E Contract Law (7 ed. Palgrave Macmillan, 2007) 55 Elliott, C & Quinn, F Contract Law (7th ed. Harlow: Longman, 2009) at 70 56 Chitty on Contract General Principles Volume 1 at 674 57 Ibid at 675

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would be deemed to be items for comfort or convenience only 58. In this instance you are not bound, but there may be some remedy available to the seller as a minor cannot simply walk from voidable contracts with the goods for which they have not paid59. The Minors Contract Act 198760 was enacted to improve the rights of an adult who makes a voidable contract with a minor.61 The golf clubs were provided to you on credit, as you are refusing to pay that debt, although the items are not necessaries and therefore not bound in contract, the law of contract does provide sanction62 for the seller. As the personal stereo is allegedly faulty S14 of Sale of Goods Act 197963 applies to the condition of the goods. When a minor pays for goods that are not deemed to be necessaries, he can only get money back in the same circumstances an adult would.64 Therefore you will have to resort to

legislation for the return of the money for the personal stereo.

Property acquired could be ordered to be returned to the seller, for example in Nash v Inman65 the minor could have been ordered to return the waistcoats to the tailor.,

58

Chitty on Contract General Principles Volume 1 at 675 Contract Law and Minors (1993) Cons L Today 16910) Supp IF iii-iv 60 Minors Contracts Act 1987 (NI equivalent Minors Contracts (NI) Order 1988) S3 (1) Where- (a) a person (the plaintiff) has after the commencement of this Act entered into a contract with another (the defendant), and (b) the contract is unenforceable against the defendant (or he repudiates it) because he was a minor when the contract was made, the court may, if it is just and equitable to do so, require the defendant to transfer to the plaintiff any property acquired by the defendant under the contract, or any property representing it. 61 Contract Law and Minors (1993) Cons L Today 16910) Supp IF iii-iv 62 th Smith, SA. The Limits of Contract Law - Atiyahs Introduction to Law of Contract (6 ed. Oxford University press, Oxford, 2006) at 4 63 Sale of Goods Act 1979 s14 (2) Where the seller sells goods in the course of a business, there is an implied term that the goods under the contract are of satisfactory quality. (2A) ...goods are of satisfactory quality if they meet the standard that a reasonable person would regard as satisfactory (2B) ..the quality of goods includes their state and condition and the following (amongst others) are in appropriate cases aspects of the quality of goods- (a) fitness for all purposes... (c) freedom from minor defects... (d) durability (and it extends to NI) 64 th Treitel, GH An Outline of the Law of Contract (6 ed. Oxford University Press, Oxford, 2004) at 230 65 Nash v Inman (1908) 2 KB 1
59

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even though the minor was not guilty of fraud... and even though there would...be no restitution at common law.66

Issue 4: Contract with local college In the event that you paid 2000 to the local college for an NVQ in Basket weaving., if this is held to be a necessary contract of service 67 to you it will be enforceable. As any service can be held to be a necessary if it satisfies the tests already stated in relation to necessary goods.68 As a person can leave school at age 16 it is only reasonable that you should be able to seek employment before reaching the age of 1869 or to fit yourself for future trade or profession.70 If it is beneficial it is enforceable;71 whereas if it is not, it will be unenforceable.72 A contract for

unnecessary education is no more binding than a contract for unnecessary goods 73 as was illustrated in Hamilton v Bennett.74 The NVQ is neither unfair75 nor for your benefit76 therefore it is not a necessary and not a binding contract. As it is not a binding contract you may be liable to return the money to the bank.

66 67

Peel, E Treitel The Law of Contract (12 ed. Sweet & Maxwell, London, 2007) at 581 Elliott, C & Quinn, F Contract Law (7th ed. Harlow: Longman, 2009) at 70 68 th Peel, E Treitel The Law of Contract (12 ed. Sweet & Maxwell, London, 2007) at 569 69 Stone, R and Cunnington, R Text, Cases and Materials on Contract Law (Routledge-Cavendish, Oxon, 2007) at 327 70 th Chitty on Contracts Volume 1 General Principles (30 Ed Thomson Reuters (Legal) Ltd 2008) at 680 quoting Clements v London and North Western Railway Company [1894] 2 Q.B. 482 Kay LJ at 491 71 Clements v London and North Western Railway Company [1894] 2 Q.B. 482 72 De Francesco v Barnum (1890) L.R. 45 Ch. D. 430 and Doyle v White City Stadium Limited [1935] 1 K.B. 110 and Chaplin v Leslie Frewin (Publishers) Ltd and Others (1966) Ch 71 (lord Denning dissenting at 91) 73 th Chitty on Contracts Volume 1 General Principles (30 Ed Thomson Reuters (Legal) Ltd 2008) at 683 74 Hamilton v Bennett (1930) 94 J PN 136 as referred to in Chitty on Contracts Volume 1 General Principles th (30 Ed Thomson Reuters (Legal) Ltd 2008) at 683 75 Leslie v Fitzpatrick 3 QBD 229 76 Clements v London and North Western Railway Company [1894] 2 Q.B. 482 and Rex v. Hindringham 6 TR 557

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It was held that the contract was beneficial to the plaintiff and not at all to the minor,77 therefore it was not enforceable, whereas in another case78 it was held to be a binding contract as it was beneficial to the minor. If applied to the current situation, De Francesco could be applied as it is not beneficial for you to undertake the NVQ as you are currently under offer of a job as a software engineer and as you claim you cannot afford to repay the loan to the bank, it would be reasonable79 of you to return the 2000 fees to the bank.

In Roberts v Gray80 the minor was held liable for repudiating the contract when it remained partly unperformed and the necessaries involved were largely educational. Stocks v Wilson81 it was held that the defendant was not liable on the contract, or in tort for deceit, but was liable to account for the 130 obtained for the goods.82

Conclusion The Law relating to minors and contracts can be unclear at times, and Elsevier argues that despite legislation83 the common law provides that children are liable on contracts for necessaries.84 Rules relating to necessaries can trap those acting in

good faith85 and a better balance is needed between protecting the minor and the interests of those of the other party. In 1982 the Law Commission proposed that all contracts should be binding on people aged over 16 and enforceable if younger than

77 78

De Francesco v Barnum (1890) L.R. 45 Ch. D. 430 Fry LJ at 443 Doyle v White City Stadium Ltd (1935) 1 KB 110 79 Steyn, J Contract Law: Fulfilling the Reasonable Expectations of Honest Men (1997) 113 LQR 433 80 Roberts V Gray [1913] 1 K.B. 520 81 Stocks v Wilson (1913) 2 KB 235 82 Stone, R and Cunnington, R Text, Cases and Materials on Contract Law (Routledge-Cavendish, Oxon, 2007) at 350 83 Sale of Goods Act 1979 84 Elsevier, R Children, Contracts and the Internet (2000) 2 EBL 9, 8 85 th McKendrick, E Contract Law (7 ed. Palgrave Macmillan, 2007) at 348

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that, but not against them.86

Treating unequal people equally only exacerbates

inequality87 so minors do need to have separate contracting legislation, as long as it also protects the adults.

Courts are now more concerned with producing justice in individual cases rather than laying down general rules.88 Steyn believes89 in using the reasonable man concept as an objective theory of contract as it promotes certainty and predictability in the resolution of contractual disputes90 The difference between opinions is that Atiyahs theory would result in some uncertainty although of course all eventualities would be covered and the courts would seek to ensure that there was no unfairness and that any sense of injustice or unfairness in contracts would be resolved either through legislation or through common law.

We will happily represent you in any future proceedings, and we look forward to hearing from you.

Yours sincerely

86 87

Elliott, C & Quinn, F Contract Law (7th ed. Harlow: Longman, 2009) at 75 Ibid at chp 1 88 Ibid at chp 1 quoting Atiyah (1979) 89 Steyn, J Contract Law: Fulfilling the Reasonable Expectations of Honest Men (1997) 113 LQR 433 at 433 90 Ibid at 433

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Bibliography Books Brownsword, R Smith & Thomas: A Casebook on Contract (12th ed Sweet & Maxwell, 2009) Chen-Wishart, W. Contract Law (2nd ed. Oxford University Press, Oxford, 2008) Chen-Wishart, W. Contract Law (3rd ed. Oxford University Press, Oxford, 2008) Online www.oxfordtextbooks.co.uk/orc/chenwishart2e/ accessed 10 November 2010 at 12.42 Chitty on Contracts Volume 1 General Principles (30th Ed Thomson Reuters (Legal) Ltd 2008) Elliott, C & Quinn, F Contract Law (7th ed. Harlow: Longman, 2009) McKendrick, E Contract Law (7th ed. Palgrave Macmillan, 2007) Peel, E Treitel: The Law of Contract (12th ed. Sweet & Maxwell, London, 2007) Smith, SA. The Limits of Contract Law - Atiyahs Introduction to Law of Contract (6th ed. Oxford University press, Oxford, 2006) Stone, R and Cunnington, R Text, Cases and Materials on Contract Law (RoutledgeCavendish, Oxon, 2007) Treitel, GH An Outline of the Law of Contract (5th ed. Butterworths, London, 1995) Treitel, GH An Outline of the Law of Contract (6th ed. Oxford University Press, Oxford, 2004) Articles Clarke, RW Contracts for the Sale of Non-Necessary Goods; Vendors Remedies Against an Infant Purchaser (1981-1983) 7 U. Tas. L. Rev. 85 Contract Law and Minors (1993) Cons L Today 16 (10) Supp IF iii-iv Elsevier, R Children, Contracts and the Internet (2000) 2 EBL 9, 8 Holroyd, J Young People The Minors Contracts Act 1987 LS Gaz 29 Jul 84 (2266) Lord Denning Recent Developments in the Doctrine of Consideration (1952) 15 MLR 1 Miles, JC The Infants Liability for Necessaries (1927) 43 LQR 389

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Steyn, J Contract Law: Fulfilling the Reasonable Expectations of Honest Men (1997) 113 LQR 433 Cases Burnard v Haggis 143 E.R. 360 Chaplin v Leslie Frewin (Publishers) Ltd and Others (1966) Ch 71 Clements v London and North Western Railway Company [1894] 2 Q.B. 482 Doyle v White City Stadium Limited [1935] 1 K.B. 110 De Francesco v Barnum (1890) L.R. 45 Ch. D. 430 Fawcett v Smethurst (1914) 1 SALK 279 Hamilton v Bennett (1930) 94 J PN 136 Harvey v Pratt (1965) 1 WLR 1025 Jennings v Rundall (1799) 101 E.R. 1419 Leslie v Fitzpatrick 3 QBD 229 Marlow v Pitfeild (1719) 2 Eq Ca Ab316 Pl 6 May Butcher v R (1934) 2 KB 17n Nash v Inman (1908) 2 KB 1 Payne v Cave (1789) 3 Term Rep 148 Peters v Fleming 151 E.R. 314 R Leslie, Limited v Sheill [1914] 3 K.B. 607 Roberts V Gray [1913] 1 K.B. 520 Ryder v Wombwell (1868-69) LR 4 Ex Scammel v Nephew Ltd v Ouston (1941) AC 251 Stocks v Wilson (1913) 2 KB 235 Valentini v Canali (1) (1890) LR 24 QBD 166 Legislation Family Law Reform Act 1969 Halsbury's Laws of England accessed 5 November 2010 at 11.12am Infants Relief Act 1874 Minors Contracts Act 1987 Minors Contracts (Northern Ireland) Order 1988 Sale of Goods Act 1979