“Tickets issued after payment cannot retrospectively introduce exclusion clauses without prior notice.”
The Court of Appeal held in favour of Chapelton. The exclusion clause was not incorporated as no reasonable notice was given before or at the time of contracting.
Chapelton hired deck chairs from Barry UDC and was given tickets after payment. He was injured when a chair collapsed and the council sought to rely on an exclusion clause printed on the ticket.
Whether an exclusion clause on a ticket issued after payment could be incorporated into the contract.
The court applied the principle that exclusion clauses must be brought to the other party's attention before or at the time of contract formation. A ticket received after payment is merely a receipt and cannot introduce new terms.
This case establishes the fundamental principle that exclusion clauses cannot be incorporated retrospectively after contract formation. It remains crucial authority on the timing requirements for incorporation of contractual terms and is essential learning for contract law students.
Exclusion clauses cannot be incorporated into a contract through tickets issued after payment, as reasonable notice must be given before or at the time of contracting.
The Court of Appeal held that the exclusion clause was not incorporated as the ticket was merely a receipt issued after contract formation.
It establishes the crucial timing requirement for incorporation of terms and demonstrates that exclusion clauses cannot be introduced retrospectively.
Put your case reading into practice. The free readiness diagnostic covers SQE1 subjects and highlights where to revise next. No account needed.
Try the free SQE1 diagnosticLord Justice Slesser, giving the lead judgment, discussed the general principles of when terms can be incorporated through tickets and notices, with MacKinnon and Goddard LJJ concurring.
OSCOLA Citation
Chapelton v Barry UDC [1940] 1 KB 532
Read the judgment for Chapelton v Barry UDC as published by The National Archives (Find Case Law).
Multiple official and mirror sources — pick whichever loads cleanly on your network.
[2026] UKSC 1
Common Room
0 comments · About the Common Room →
No comments yet — start the discussion.
Voted-best comments help future students and feed Caselaw's AI study tools.