Here are expanded answers for the provided case studies under the Sales of Goods Act 1930
with detailed explanations.
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Case Study 1: Rowland v. Divall (1923)
Facts Recap:
The buyer purchased a car from a seller who claimed ownership. Later, the car was discovered
to be stolen, and the true owner reclaimed it. The buyer sued the seller to recover the full
purchase price, arguing that they never actually obtained ownership of the car.
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Judgment-Based Questions and Answers
1. Q: Did the seller have the right to sell the car? Why or why not?
Answer:
No, the seller did not have the right to sell the car because they were not the legal owner.
According to Section 27 of the Sales of Goods Act 1930, only a person with valid ownership or
authority can transfer ownership to another party. Since the seller sold a stolen car, they had no
legal title to pass on to the buyer. This principle ensures that property rights are respected, and
stolen goods cannot legally enter into commerce.
2. Q: Can the buyer claim a refund of the purchase price? Why?
Answer:
Yes, the buyer is entitled to a full refund of the purchase price. This is because the seller failed
to fulfill the essential condition of the sale: transferring ownership. Under the Act, the contract is
void if ownership is not legally transferred. The buyer paid for ownership and possession, but
since ownership was never transferred, the seller must return the money.
3. Q: How does this case highlight the importance of ownership in a valid sale?
Answer:
This case emphasizes that ownership is fundamental in a contract of sale. The buyer expects
not just physical possession but also legal ownership of the goods. Without ownership, the
transaction fails to meet the legal definition of a "sale" under the Act. The case protects buyers
from losing their money when a seller has no legal right to sell the goods in question.
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Case Study 2: Aldridge v. Johnson (1857)
Facts Recap:
A buyer placed an order for a specified quality of barley, but the seller delivered barley of inferior
quality. The buyer rejected the goods and sued the seller for breach of contract.
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Judgment-Based Questions and Answers
1. Q: Did the seller breach the contract? Why or why not?
Answer:
Yes, the seller breached the contract by delivering goods that did not match the agreed
description and quality. Section 15 of the Sales of Goods Act requires that goods correspond
with the description in the contract. The seller’s failure to deliver the agreed quality constitutes a
breach of an implied condition, entitling the buyer to reject the goods and seek remedies.
2. Q: Was the buyer justified in rejecting the goods? Why?
Answer:
Yes, the buyer was fully justified in rejecting the goods because they did not conform to the
terms of the contract. Under the Act, the buyer has the right to refuse goods that do not meet
the description or quality standards. This protects buyers from being forced to accept
substandard products that could harm their business or personal interests.
3. Q: What remedies are available to the buyer in this case?
Answer:
The buyer can sue the seller for damages resulting from the breach of contract. This includes
compensation for any additional costs incurred to source the correct quality of barley elsewhere.
The case underscores the seller’s obligation to adhere strictly to contract terms and the buyer’s
right to enforce these terms.
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Case Study 3: Phillips v. Brooks Ltd. (1919)
Facts Recap:
A fraudster purchased jewelry from a jeweler by pretending to be a reputable customer and
paying with a fraudulent check. The fraudster then sold the jewelry to an innocent third party.
The jeweler attempted to reclaim the jewelry from the third party.
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Judgment-Based Questions and Answers
1. Q: Was the jeweler entitled to recover the jewelry from the third party? Why or why not?
Answer:
No, the jeweler was not entitled to recover the jewelry from the third party. Section 27 of the
Sales of Goods Act states that if a third party purchases goods in good faith and without
knowledge of defects in the seller’s title, they acquire a valid title to the goods. In this case, the
third party was an innocent purchaser with no knowledge of the fraud, and their rights were
protected under the law.
2. Q: How does this case relate to the concept of "good faith" in sales?
Answer:
This case highlights the importance of good faith in commercial transactions. Good faith
protects innocent buyers who purchase goods without knowledge of fraud or defects in the
seller’s title. This principle promotes trust in the marketplace by ensuring that transactions
conducted honestly are upheld.
3. Q: What legal action could the jeweler take to recover their losses?
Answer:
The jeweler’s legal recourse is to sue the fraudster for damages. However, this may not be
effective if the fraudster is untraceable or insolvent. The case underscores the risks associated
with accepting unsecured payment methods like checks, particularly in high-value transactions.
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Case Study 4: Great Western Railway Co. v. McCarthy (1871)
Facts Recap:
A buyer ordered goods to be delivered at a specific time and place, but the seller failed to
deliver them on time. As a result, the buyer suffered business losses and sued for damages.
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Judgment-Based Questions and Answers
1. Q: Did the seller breach the contract? Why or why not?
Answer:
Yes, the seller breached the contract by failing to deliver the goods as agreed. Under the Sales
of Goods Act, timely delivery is a fundamental condition of the contract if specified. The seller’s
failure to meet this condition entitles the buyer to seek remedies for the breach.
2. Q: Can the buyer claim damages for the loss of business opportunities? Why?
Answer:
Yes, the buyer can claim damages for foreseeable losses, including lost business opportunities.
The seller’s breach caused these losses directly, making them eligible for compensation under
the Act. The buyer must prove that the losses were a natural consequence of the delay and
were within the reasonable contemplation of both parties when the contract was made.
3. Q: What principles of the Sales of Goods Act are applied in this case?
Answer:
This case applies the principles of timely delivery and the right to recover damages for breach of
contract. It also reinforces the importance of treating delivery terms as conditions rather than
warranties when they are essential to the contract’s purpose.
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Case Study 5: Frost v. Aylesbury Dairy Co. Ltd. (1905)
Facts Recap:
A dairy sold milk contaminated with harmful bacteria, causing the buyer to suffer severe health
issues. The buyer sued the dairy, arguing that the milk was not fit for consumption.
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Judgment-Based Questions and Answers
1. Q: Did the seller breach the contract? Why or why not?
Answer:
Yes, the seller breached the contract by supplying goods that were not of merchantable quality.
Section 16 of the Sales of Goods Act requires goods to be fit for their intended purpose. The
contaminated milk failed this standard, making the seller liable for the breach.
2. Q: What remedies can the buyer seek in this case?
Answer:
The buyer can seek damages to cover medical expenses, compensation for pain and suffering,
and any other losses resulting from the breach. They may also demand a refund for the
purchase price. These remedies ensure that sellers are held accountable for the safety and
quality of their goods.
3. Q: How does this case illustrate the importance of merchantable quality?
Answer:
This case highlights the seller’s legal obligation to provide goods that meet basic safety and
quality standards. It also underscores the buyer’s right to expect that the goods they purchase
are safe to use or consume.
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These expanded answers provide a deeper understanding of the Sales of Goods Act 1930 and
its practical applications. Let me know if you'd like more examples!
