Smith v Hughes [1871]

Court: Queen’s Bench

Facts: Mr Hughes, a horse trainer, purchased oats from Smith based on a sample shown. Hughes mistakenly identified the type of oats and found that they were not suitable for his horses. Smith sued Hughes to enforce the contract, arguing that the oats were as described.

Issue: Can a contract be rescinded due to a unilateral mistake if the buyer misidentifies the type of goods, provided there was no fraud or deceit by the seller?

Held: The court ruled that the contract was binding despite Hughes’ mistaken belief about the type of oats. Blackburn J held that the contract was enforceable as long as there was no fraud or deceit, and that the buyer must take the goods as delivered if they conform to the contract, even if the buyer made a mistake.

Key Judicial Statement: Blackburn J noted, "The buyer must take the goods as they are, unless there is fraud or deceit by the seller. The contract remains binding even if the buyer's belief about the goods is mistaken."

💡Leveluplaw: The principle established is that unilateral mistakes do not generally invalidate a contract unless fraud or deceit is involved. Buyers must accept goods as per the contract’s terms, emphasizing the importance of careful inspection and due diligence.