Grogan v Robin Meredith Plant Hire [1996] CLC 1127

Established that all the circumstances ought be considered in determining a document’s contractual validity; subsequently, usually a timesheet ought not be viewed as a contract.


The claimant, Grogan, was an employee of the defendant’s, Robin Meredith Plant Hire, and had signed an employment contract with them. The defendant required that the claimant use and sign a timesheet, upon which they had printed additional terms, which were intended to incorporate terms by reference. The defendant attempted to assert that these additional terms ought be binding upon employees, whilst the claimant counter-claimed that as one would not reasonably expect for contractual terms to be found on a timesheet, they ought not be deemed a binding contractual promise that varied the original employment contract.


Whether an employee already subject to an initial employment contract could be further bound by a contractual term printed upon a timesheet that they were required to sign.


Further, Auld LJ stated that a timesheet was more appropriately termed an administrative document than a contractual one, and thus the average reasonable person would not expect that any conditions stated on it are contractual in nature. Rather, timesheets serve as an administrative record of the performance of an already existent obligation by a party. Thus, despite that the timesheet was a formal document containing the signatures of both parties, Courts ought to also have consideration for the circumstances of and intentions regarding the document in determining whether it ought be legally binding.

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