More in Expectation than Hope: The Blackpool Airport Case

Abstract

As it will be recalled, in Williasns v RoJ0fey Bros and NicXlolls (Contractor.v) Ltd,l the Court of Appeal decided that an express promise by A to B, to pay B an additional sum if B carried out his existing contractual obligations to A, could be contractually binding. Although Williams v RoJjrey plainly signalled that dersimental reliance by the promisee is not essential for a promise to be binding, its broader significance is less clear. On one interpretation, it simply effected a minor modification to the traditional consideration requirement, treating promises as contlactually binding provided that the promisor obtains some reciprocal besleft from the promisee. Another view is that it indicated that promises n ay be contractually binding provided that the promisee reasonably relies on the promise. And, accordillg to yet anc)ther reading, it signified that promises may be contractually binding provided that the promisee reasonably expects the promisor to keep his word. Although this last l-eading is the most radical one, it can now derive some indilect support from the COUlt'S more recent decision in Blackpool and Fylde Aezo Club v Blackpool Borougll Council.2 In this note, we will consider the Blackpool case with a view to clarifying both the idea of reasonable expectation and the significance of general judicial ideologies.