Robinson v Balmain New Ferry Co Ltd [1910] AC 295

Facts

  • Mr. Robinson entered the wharf operated by Balmain New Ferry Company under an agreement that required payment of a toll for exiting.
  • After entering, Mr. Robinson changed his mind and sought to leave the wharf without paying the exit toll.
  • Employees of the ferry company physically prevented Mr. Robinson from leaving until he paid the toll or until a ferry departed.
  • Mr. Robinson brought an action against the ferry company, alleging false imprisonment and assault.

Issues

  1. Whether physically preventing Mr. Robinson from leaving the wharf without paying the required toll amounted to false imprisonment.
  2. Whether the ferry company’s enforcement of the exit toll condition was a reasonable and lawful restriction on Mr. Robinson's liberty.

Decision

  • The Privy Council ruled against Mr. Robinson’s claim.
  • The court held that the exit toll was a reasonable contractual condition known and accepted by Mr. Robinson upon entry.
  • The actions of the ferry company in preventing exit without payment were considered a valid enforcement of this condition and not an instance of unlawful detention.
  • The company's restriction of movement was deemed reasonable and proportionate to the circumstances.

Legal Principles

  • False imprisonment requires complete restraint of movement without lawful justification and with intent to detain.
  • Businesses may impose and enforce reasonable, clearly communicated contractual conditions limiting movement, provided these are known and accepted by entrants.
  • Physical restraint to enforce a legitimate and reasonable contractual agreement does not amount to false imprisonment.
  • The context and existence of agreements are critical to evaluating claims of false imprisonment in commercial situations.
  • The doctrine of volenti non fit injuria (voluntary assumption of risk) can apply where individuals knowingly accept certain restrictions.
  • General principles for intentional torts highlight the importance of intent, reasonableness, consent, and proportionality.

Conclusion

Robinson v Balmain New Ferry Co Ltd [1910] AC 295 clarifies that the enforcement of reasonable, known contractual conditions by a business does not constitute false imprisonment, provided the terms are clear, proportionate, and understood at the outset. The case draws an important distinction between unlawful detention and legitimate business practices consistent with prior agreement.

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