Gallie v Lee: HL 1971

Lord Wilberforce said that the principles of non est factum are designed to protect also innocent third parties who may rely upon a document signed apparently correctly.

Judges:

Lord Wilberforce

Citations:

[1971] AC 1004

Jurisdiction:

England and Wales

Citing:

Appeal fromGallie v Lee CA 1969
A deed bearing a false signature is a forgery and creates no rights at all. ‘If the deed was not his deed at all (non est factum), he is not bound by his signature any more than he is bound by a forgery. The document is a nullity just as if a rogue . .
CriticisedSowler v Potter 1939
The defendant had been convicted of an offence of permitting disorderly conduct in a cafe, under her proper name of Ann Robinson. She then assumed the name of Ann Potter. The plaintiff’s evidence was that, if he had known that she was Ann Robinson, . .
CitedCarlisle and Cumberland Banking Company v Bragg 1911
A party wishing to establish a plea of non est factum in order to avoid liability under a deed, must show that he had taken care in signing the document.
Held: There could not be negligence in the execution of a document unless a duty was owed . .

Cited by:

MentionedChagos Islanders v The Attorney General, Her Majesty’s British Indian Ocean Territory Commissioner QBD 9-Oct-2003
The Chagos Islands had been a British dependent territory since 1814. The British government repatriated the islanders in the 1960s, and the Ilois now sought damages for their wrongful displacement, misfeasance, deceit, negligence and to establish a . .
Lists of cited by and citing cases may be incomplete.

Contract

Updated: 06 May 2022; Ref: scu.186673