1. Facts of the Case
A customer approached a self-operating car parking machine installed by a parking facility. The machine, acting on behalf of the owner/operator of the car park, invited customers to park their vehicles. The customer inserted the required payment into the machine and, in return, received a claim ticket indicating terms of use and granting the right to park in the designated area.
The transaction was fully automated, with no direct human interaction between the customer and the car park owner. The question arises as to whether a valid contract exists in this situation, given the involvement of a machine and the absence of written or oral agreement.
2. Issues in the Case
- Does the transaction between the customer and the parking machine constitute a valid and enforceable contract?
- Are the essential elements of a valid contract present in this automated interaction?
- Can a machine act as an agent or representative of the owner to form contractual obligations?
3. Legal Principles Covered
- Indian Contract Act, 1872 (applicable principles also align with common law principles globally):
- Section 2(h): A contract is an agreement enforceable by law.
- Section 10: Essentials of a valid contract include:
- Offer and acceptance
- Lawful consideration
- Intention to create legal relations
- Capacity of parties
- Lawful object
- Free consent
- Offer and Acceptance:
- The parking machine displays terms and invites payment (Offer).
- Customer inserts money and takes a ticket (Acceptance).
- Consideration:
- Money paid by the customer for a parking service constitutes valid consideration.
- Consensus ad idem (Meeting of minds):
- The customer clearly understands he is paying for a parking facility and accepts the terms by using the machine.
- Relevant Case Law:
- Thornton v. Shoe Lane Parking Ltd. (1971): Held that a valid contract was formed the moment the customer inserted money into the machine and took the ticket.
- Machines can bind parties into contracts just as human agents would, provided the customer has reasonable notice of the terms.
4. Possible Judgement
Based on the legal principles and facts, a valid contract exists in this transaction. The essentials of a valid contract are satisfied:
- The offer was made through the machine on behalf of the owner.
- The acceptance was through the customer’s act of payment and taking the claim ticket.
- Consideration was exchanged (money for parking).
- The transaction was made with legal intent, and both parties (implicitly) consented.
- The machine legally represents the owner’s intention to contract.
Therefore, the contract is enforceable, and any breach of the terms stated on the ticket or failure of service could give rise to contractual liability on the part of the car park owner.
