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Distinguishing Contractual Terms from Mere Representations

4LW003 Contract Law Terms of the Contract Outline Notes Contractual Terms Terms of the contract will determine the respective contractual obligations of the parties. Terms and mere representations - Part 1 It is important to determine whether a statement (oral or written) is part of the agreement or whether it merely precedes the agreement. Statements which induce a contract are called mere representations (misrepresentation) and must be distinguished from terms of a contract which form part of the contract. When construing a contract and when determining whether a pre-contractual statement is a representation or a term, the courts adopt an objective analysis of the parties' intentions. Chartbrook Ltd v Persimmon Homes Ltd [2009] Oceanbulk Shipping and Trading SA v TMT Asia Ltd and Others [2010] Rainy Sky SA and others v Kookmin Bank [2011] Courts have developed a kind of 'checklist' to help determine whether a statement is a term or a mere representation. Judicial checklist/guidelines Timing of the statement At what stage of the negotiations was the statement made? As a general rule, the more time that elapses between the statement being made and the contract being concluded, the less likely it is that the statement is a term. Bannerman v White (1861) Schawel v Reade [1913] cf. Routledge v McKay [1954] Importance of the statement What importance was attached to the statement by the parties? A statement may be regarded as a term if such importance is attached to it that the injured party would not have entered into the contract but for the statement. Bannerman v White (1861) Couchman v Hill [1947] cf. Oscar Chess Ltd v Williams [1957] Strength of the inducement What was the strength of the inducement of the statement? The more emphatically a statement is made, the more likely it is that the statement will be a term. Eg. did the maker of the statement accept responsibility for the statement, or did they advise the other party to verify it? Schawel v Reade [1913] Ecay v Godfrey (1947) Special knowledge or skill Did the maker of the statement have special knowledge or skill, as compared to the other person? Where a statement is made by someone who has expert knowledge or skill that is relevant to the subject in hand, it is more likely that the statement will be a term. Harling v Eddy [1951] Dick Bentley Productions Ltd v Harold Smith (Motors) Ltd [1965] cf. Oscar Chess Ltd v Williams [1957] Reduction into writing Was the oral statement reduced to writing? If there has been an oral agreement which has later been reduced into a written contract, any statement that appears in the written contract will usually be regarded as a term. Conversely, any statement which is not included in the written contract is likely to be a mere representation. Routledge v Mackay [1954] Chartbrook Ltd v Persimmon Homes Ltd [2009] Parol Evidence Rule Where there is a written contract, the general rule is that extrinsic (parol) evidence will not be admitted