Background: This case involves Mr. Balfour, a British civil servant, and his wife, Mrs. Balfour. While the couple was residing in Ceylon (now Sri Lanka), Mrs. Balfour fell ill and returned to England for medical treatment. Mr. Balfour promised to send her £30 a month for maintenance until she recovered. However, their relationship deteriorated, and Mr. Balfour stopped sending the payments. Mrs. Balfour sued him for breach of contract.
Key Issue: The central issue was whether Mr. Balfour’s promise to provide financial support constituted a legally enforceable contract or merely a domestic arrangement.
Arguments:
Mrs. Balfour’s Argument: Mrs. Balfour claimed that her husband’s promise to send her monthly maintenance constituted a binding contract, which he breached by stopping the payments.
Mr. Balfour’s Argument: Mr. Balfour argued that the agreement between them was purely a domestic arrangement, not intended to have legal consequences, and thus not enforceable in court.
Judgment: The Court of Appeal ruled in favor of Mr. Balfour. The court held that agreements between spouses made in the context of their domestic life are generally not intended to create legally enforceable obligations. As such, the promise was a private family arrangement, not a contract.
Significance: This case established the principle that domestic agreements between spouses, particularly those made in a familial or personal context, are not typically considered legally binding. It marked a clear distinction between social agreements and enforceable contracts in English contract law.
