Leeds Rugby Ltd v Harris [2005] EWHC 1591

Contract Law – Enforceability – Consideration – Reasonableness of Restraint of Trade Covenant – Uncertainty


Iestyn Harris played rugby league for Leeds Rhinos and was contracted to play for them for four years. However, he wished to switch codes and play Rugby Union in order to be selected for the Welsh national rugby team for the upcoming Rugby World Cup tournament. To this end, Leeds arranged a transfer with Cardiff, and formed an agreement with Harris which included a clause that required Harris to return to play for Leeds if he exercised an option to return to Rugby League. Harris decided to return to Rugby League, but instead of joining Leeds, joined the Bradford Bulls.


Was the clause in the option requiring Harris to return to play for Leeds effective? Whether or not there was valid consideration for the agreement to be upheld. Whether or not, if there was valid consideration, the restraint of trade clause was reasonable. Whether or not the contract was void for uncertainty.


There was valid consideration from Leeds and from Harris to allow the agreement to be upheld by the court. Whilst damages were difficult to quantify, the term itself requiring Harris to return to Leeds was conceptually clear, and so the agreement was not void for uncertainty. Finally, the restraint of trade clause was not unreasonable considering that it had allowed Harris to escape his contract with Leeds in the first place in order solely to switch codes and play Rugby Union to ensure he could play in the Rugby World Cup. Furthermore, the clause provided that Harris would not be any worse off under his contract with Leeds than he would have been at Cardiff should he decide to exercise the option as Leeds were obliged to match his Cardiff pay. Because of this, it was not unreasonable and was capable of being upheld.