Law Case Summary
Robinson v Balmain New Ferry Co. Ltd [1910] AC 295
False imprisonment – contract relating to entry and exist from a ferry wharf
Facts
Robinson (R) paid a penny to cross on a ferry, however he narrowly missed the ferry and changed his mind about crossing. R attempted to leave through the gate he came through, however it required another penny to be paid to leave. R refused to pay the penny because he had not crossed on the ferry. Balmain New Ferry Co. (D) forcibly prevented R from leaving until he paid the penny. R raised an action for false imprisonment.
Issue
R claimed that he was falsely imprisoned due to the forcible prevention of his leaving the ferry wharf without paying a penny to leave.
Decision / Outcome
A person can be legitimately prevented from leaving if they had entered an earlier contracted permitting so. When R entered the ferry gate, he agreed to pay a penny on both entering and leaving the ferry. This bound him to a contract and D was entitled to impose a reasonable condition before allowing him to pass through their turnstile from a place to which he had gone of his own free will. This case narrows the law on false imprisonment, following the case of Bird v. Jones [1845] 7 QB 742 in which it was held that false imprisonment is constituted by total (and not partial) obstruction, however in the present case it is held that it even where a person is totally obstructed it will not constitute false imprisonment if there is a reasonable condition to passing.
Updated 20 March 2026
This case summary accurately describes the facts, issue, and outcome of Robinson v Balmain New Ferry Co. Ltd [1910] AC 295. The legal principle that a contractually agreed condition restricting exit does not constitute false imprisonment remains good law in the UK. The reference to Bird v Jones (1845) 7 QB 742 is also accurate as an authority on the requirement of total restraint for false imprisonment. No subsequent legislation or case law has overturned or materially altered these principles. The summary remains broadly reliable for students studying the tort of false imprisonment, though readers should note that the broader law of false imprisonment and unlawful detention has been developed in later cases, including in the human rights context under the Human Rights Act 1998 (particularly Article 5 ECHR), which may be relevant depending on the context of study.
