Gibson v Manchester City Council (MCC)

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This is case is concerned with the Invitation to treat (ITT) in the offer and acceptance chapter of contract law.

Facts of Gibson v Manchester City Council (MCC)

A Conservative party was offering to sell houses at very reasonable rates. And made very easy for tenants to fill the form and apply for houses.

Gibson filled the Form, to which Manchester city council replied “We may be prepared to sell the house for Price X”. If you are interested make a formal application.

Gibson made the application but left the price clause empty. He asked whether it had been taken into consideration that the path before the house was broken.

The Council responded that the price had been fixed. According to the condition of the property Mr. Gibson asked the council to continue his application, But the council took out the house from the list.

Then the Labour party came into force, and said that they would not sell houses unless a binding contract had been concluded.


Whether there was a valid contract between MR. Gibson and the Council?


Firstly the Trial Court and Court of Appeal (COA) held that there was a contract, based on the decision of Storer v MCC, but when the case was referred to House of Lords (HOL).

They said that there was no contract as the words used by council “maybe prepared to sell” was not an offer, As it did not commit the council to selling the house it was simply an Invitation to treat (ITT)

Important Points of Gibson v Manchester city Council (MCC)

Any statement made for the invitation to make an offer is not an offer, but an invitation to treat (ITT).

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