Tuesday, March 4, 2014

A New Regime "Contracts of Adhesion": Unconscionability of Bargain?

(The author of this post is Paridhi Poddar, a 1st year student of the West Bengal National University of Juridical Sciences, Kolkata. She can be contacted at paridhipari04@gmail.com)

Introduction: Adhesion Contracts

Contracts of adhesion, simply put, are contracts containing a set of standard terms and conditions presented on a take-or-leave basis thereby eliminating the scope and need for negotiations between the contracting parties. In the day-to-day sense, one comes across such contracts during the purchase of insurance policies, license agreements, online software etc. Adhesion contracts incorporate terms which are derived from common business experience and do not allow for any customisation as per the needs of the other party. Sometimes, such contracts are formed through shrink wrap or click wrap agreements.[1] As a result, such contracts are sometimes also termed as “boilerplate contracts” or “private legislation.”[2] In its 103rd report of 1984, the Law Commission of India has even gone to the extent of calling these as “pretended contracts.” This is true because such contracts become problematic to the basic tenets of contract law when they evince unconscionable manipulation of the bargaining powers of the contracting parties. On the other hand, since adhesion contracts evolve through business usage and practice, they import efficacy in commercial bargains by reducing costs in transactions to a large extent. Even after having some of these advantages, the probable presence of unconscionability in adhesive contracts has urged the judges to critically think about the notions of freedom of contract and “pact sunt servanda”. This article would introduce you to the position of Indian law on the enforceability and the binding nature of such contracts.

Unconscionability of bargain: The test

A contract comes into existence on the grounds of consensus-ad-idem when the consumer “accepts” or “agrees” to the terms. Hence, when firms in the market intend to do business on the basis of standard contracts, the presumption of the court is that there is nothing unconscionable about such a transaction per se.[3] Thus, the courts have never held that all forms of standard contracts would be struck down as unenforceable. For instance, in Ferro Alloys Corpn. Ltd. v. A.P. State Electricity Board,[4] where the terms of the contract provided that no interest would be provided on the security deposit made by the consumers with the board, the court held that such a term was not arbitrary but reasonable on the grounds of statutory validation. As a result, since such a term did not shock the conscience of the Court, it was not declared to be void.

But, the practical problem associated with such contracts is that they are drafted so lengthily and in such a complicated manner that they are rarely read. It is thus an admitted fact that when standard terms are presented before any party, they are most often neither read nor negotiated by him. The courts of equity have recognised that such contracts often give giant multi-nationals and other companies opportunities to exploit the vulnerable classes by subjecting them to harsh, arbitrary and inequitable terms. Hence, in the growing sociological dimension of the contract law, where it becomes clear that the terms would not have been agreed to by a reasonable minded person, the courts often resort to reviewing the contracts. For this, courts have employed the test of “unconscionability” to protect the interest of this group. The doctrine of unconscionability is an off-shoot of the Roman maxim “laesio enormous” which means that a contract which is so onerous that one of the parties would be overreached by the other need not be performed. Thus, if it is proved that the free consent within the meaning of section 14 of the Indian Contract Act was absent or when the terms were so unfair and unreasonable that they could “shock the conscience of the court",[5] the court would strike down such term. In order to evaluate the unconscionability, the courts investigate whether the terms of the contract had the effect of grossly manipulating the inferior bargaining powers of the parties to obtain an “unreasonably favourable” advantage for the other party.[6] Such contracts are not only vitiated on grounds of lack of true consent but they also impugn the sacrosanct notion of “freedom to contract.” This is especially true when they are entered into by a party under economic duress (as in the case of employment contracts) or due to lack of any meaningful choice( for example, in consumer contracts). For instance, in the case of employment contracts, the courts have had a general tendency to assume inequality of bargaining power primarily because an employee may not have any meaningful choice at the time of accepting the conditions of the employment. Hence, he may consent to contract due to the exigencies of economic duress.[7] For example, in LIC of India v. Consumer Education Research Centre,[8] the court held a standard insurance policy, which contained a term by which the benefit of the insurance would  accrue only to salaried class in government and firms, as being unconscionable.

But, this does not imply that a court would render a contract inoperative merely on the ground of inequality of bargaining powers. For example, in case of commercial transactions where contracts are formed by two business firms, even though parties may be of varied economic status, there is no presumption of unconscionability. Another test that is employed by the courts to determine if an adhesive contract is unconscionable is to find whether the “consideration is so grossly inadequate” that a reasonable person would not have gotten into it.[9]

Once any term in a standard contract is found to be unconscionable, the courts have been of the opinion that such contracts are void as being opposed to public policy under section 23 of the Indian Contract Act. In Central Inland Water Transportation v. Brojo Nath Ganguly[10], the standard terms of employment contained a term empowering the employer to sack the employee without conducting any inquiry. The term was held to be a bad bargain and was declared to be void and unenforceable.  This was because such a clause in the contract had the effect of threatening the right to employment of a large number of governmental employees, and would have amounted to an injury to public interest. Thus, the courts prefer to declare unconscionable contracts void also to avoid a multiplicity of litigation which would crop if the contract is only declared as voidable under section 16 of the Act.

Recommendations of the Law Comission in its 103rd Report[11]

The Law Commission report admits that barring judicial attempts, the Indian Contract Act does not provide any time for nullifying such contracts. Thus, it has recommended a new chapter on adhesion contracts to be included in the act itself. It has been recommended by the Commission that besides investigating into the reasonableness of standard terms, if any term exempts the parties from (i) liability for wilful breach of the contract or, (ii) the consequences of negligence, that would prima facie be held to be “unconscionable” and should be made inoperative.

Thus, in its jurisprudential sense, the entire doctrine with regard to adhesion contract hinges on the ground that “pacta sunt servanda” does not imply that even unreasonable contracts should be enforced. Secondly, it also suggests that the freedom to contract should not mean that it can be abused. As a result, when one falls prey to the standard terms in a business contract, unconscionability serves as a good defence provided one can prove the contract to be prejudicial for “shocking the conscience” of the court.



[1] Shrink wrap agreements are those where the terms of purchase of a license of a software are read by the customer only when the package is open, whereas the opening of the package signifies an acceptance of these terms. Similarly, click wrap agreements are those where the sale is completed by click on the button which states “I agree” to the terms stated thereof.
[2] Thornton v. Shoe Lane Parking Ltd., 1971 2 QB 163, per Lord Denning.
[3] Lekh Raj v. State of Rajasthan, 1987 1 WLN 774.
[4] AIR 1993 SC 2005.
[5] Id.
[6] Central Inland Water Transportation v. Brojo Nath Ganguly, AIR 1986 SC 1517, 81. V. Raghunadha Rao v. State of A.P., 1 A.L.T. 461
[7] See generally Superintendence Company of India Pvt. Ltd. v. Sh. Krishan Murgai, AIR 1980 SC 1717.
[8] AIR 1995 SC 1811.
[9] But see Indian Contract Act, 1872, §25 (adequacy of consideration is not a primary factor, however,if it so inadequate that it becomes unreasonable for a person to be bound by it).
[10] 1986 AIR 1571.

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