See . The assumpsit or > promise was founded "not upon any fiction of law, but upon an interpretation > of facts by the court which led it to the genuine conclusion that the > parties had actually agreed (to make the payment)". 27\. The second is the > decision at around the same time that indebitatus assumpsit lay in > circumstances where the assumpsit was necessarily imputed rather than > genuinely implied from the facts.See ; .
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The question that arose in the 16th century was whether assumpsit could be brought in lieu of debt.See generally, Professor David Ibbetson, Historical Introduction to the Law of Obligations (2nd ed). For a plaintiff, assumpsit was the more desirable course: the defendant would not be able to elect to wage his law as he would in debt sur contract. In order to bring assumpsit, the plaintiff would plead that, the defendant being indebted to the plaintiff, the defendant had later promised to pay the debt.
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Simpson (2004) p.70 The conservative Common Pleas, through the appellate court the Court of Exchequer Chamber, began to overrule decisions made by the King's Bench on assumpsit, causing friction between the courts.Simpson (2004) p.71 In Slade's Case, the Chief Justice of the King's Bench, John Popham, deliberately provoked the Common Pleas into bringing an assumpsit action to a higher court where the Justices of the King's Bench could vote, allowing them to overrule the Common Pleas and establish assumpsit as the main contractual action.
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See 1 Corbin on Contracts (rev. ed.1993) § 1.18, at p. 53 (footnote omitted). This count is considered a type of assumpsit.
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Popham ruled that assumpsit claims were valid, a decision called a "watershed" moment in English law, with archaic and outdated principles being overwritten by the modern and effective assumpsit, which soon became the main cause of action in contract cases. This is also seen as an example of judicial legislation, with the courts making a revolutionary decision Parliament had failed to make.
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Lord Mansfield CJ dealt with a number of objections to allowing the plaintiff's action in Assumpsit. Firstly, he noted the objection "That an Action of Debt would not lie here and no Assumpsit will lie, where an Action of Debt may not be brought"; and responded that the rule was "That an Action of Assumpsit WILL lie in many cases where Debt lies and in many where it does not lie."Moses v Macferlan (1760) 2 Bur 1005 at 1008. Secondly, he dealt with the objection, "That no Assumpsit lies, except upon an express or implied Contract"; answering "If the Defendant be under an Obligation, from the Ties of natural Justice, to refund; the Law implies a Debt, and gives this Action, founded in the Equity of the Plaintiff's Case, as it were upon a Contract".
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Assumpsit ("he has undertaken", from Latin, assumere), or more fully, action in assumpsit, was a form of action at common law used to enforce what are now called obligations arising in tort and contract; and in some common law jurisdictions, unjust enrichment. The origins of the action can be traced to the 14th century, when litigants seeking justice in the royal courts turned from the writs of covenant and debt to the trespass on the case. Most significantly, the modern law of contracts and the law concerning unjust enrichment began to emerge in the 19th century out of the law relative to actions in assumpsit.
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Lampleigh v Braithwait [1615] EWHC KB J 17, (1615) Hobart 105, 80 ER 255 is a case on implied assumpsit and past consideration in English contract law.
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D Ibbetson, 'Sixteenth Century Contract Law: Slade's Case in Context' (1984) 4(3) Oxford Journal of Legal Studies 295, 296 But if a claimant wanted to simply demand payment of the contractual debt (rather than a subsequent promise to pay) he could have to risk a wager of law. The judges of the Court of the King's Bench was prepared to allow "assumpsit" actions (for obligations being assumed) simply from proof of the original agreement.See further, AWB Simpson, A History of the Common Law of Contract: the Rise of the Action of Assumpsit (1987) With a majority in the Exchequer Chamber, after six years Lord Popham CJ held that "every contract importeth in itself an Assumpsit".See further, JH Baker, 'New Light on Slade's Case' (1971) 29 Cambridge Law Journal 51 Around the same time the Common Pleas indicated a different limit for contract enforcement in Bret v JS,(1600) Cro Eliz 756 that "natural affection of itself is not a sufficient consideration to ground an assumpsit" and there had to be some "express quid pro quo".
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D. Ibbetson, 'Sixteenth Century Contract Law: Slade's Case in Context' (1984) 4(3) Oxford Journal of Legal Studies 295, 296 But if a claimant wanted to simply demand payment of the contractual debt (rather than a subsequent promise to pay) he could have to risk a wager of law. The judges of the Court of the King's Bench was prepared to allow "assumpsit" actions (for obligations being assumed) simply from proof of the original agreement.See further, A. W. B. Simpson, A History of the Common Law of Contract: the Rise of the Action of Assumpsit (1987) With a majority in the Exchquer Chamber, after six years Lord Popham CJ held that "every contract importeth in itself an Assumpsit".See further, J. H. Baker, ‘New Light on Slade's Case’ (1971) 29 Cambridge Law Journal 51 Around the same time the Common Pleas indicated a different limit for contract enforcement in Bret v JS,(1600) Cro Eliz 756 that "natural affection of itself is not a sufficient consideration to ground an assumpsit" and there had to be some "express quid pro quo".
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71 In Slade's Case, the Chief Justice of the King's Bench, John Popham, deliberately provoked the Common Pleas into bringing an assumpsit action to a higher court where the Justices of the King's Bench could vote, allowing them to overrule the Common Pleas and establish assumpsit as the main contractual action.Boyer (2003) p.127 After the death of Edmund Anderson, the more activist Francis Gawdy became Chief Justice of the Common Pleas, which briefly led to a less reactionary and more revolutionary Common Pleas.Ibbetson (1984) p.
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No wager of law was allowed in assumpsit, even though the cause of action were a simple debt. This led to the general adoption of assumpsit - proceeding originally upon a fictitious averment of a promise by the defendant - as a means of recovering debts. Where a penalty was created by statute, it became a common form to insert a proviso that no wager of law was to be allowed in an action for the penalty. Wager of law was finally abolished in 18 33 (3 & 4 William IV. c. 42).
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The traces of the law relating to assumpsit are still felt today, particularly in the law of contract and unjust enrichment. For example, consideration is only necessary in relation to simple contracts. Where a claimant brings an action in contract for non-performance of a promise contained in a deed, there is no need to show that the claimant supplied consideration for the promise. The reason for this is historical: where there was no deed, the correct action was assumpsit for nonfeasance; in the latter, in debt sur obligation.
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Eventually, in November 1602, Popham issued a judgment on behalf of the court which stated "Firstly, that every contract executory implies in itself a promise or assumpsit. Secondly, that although upon such a contract an action of debt lies, the plaintiff may well have an action in the case upon the assumpsit." Coke, in his report of the case (published in 1604) reports that the judgment was unanimous, while more modern commentators such as Boyer assert that it was narrow, most likely 6 to 5, with the dividing line being between the King's Bench judges and Common Pleas.
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Action in trover became fully defined during the reign of Elizabeth I of England. Trover has been described as an action in assumpsit which arose from the quare writs by adding the cum (Latin: "with") which, then could allege that the defendant undertook (assumpsit, "assumed the risk", or "assumed the duty"), to do something. Another clause which followed some time later contained the allegation of trover, and deals with situations which involved neither bailment nor a trespassory taking. In Bracton's day the appeal of larceny could be changed into an action de re adirata by omitting the words of felony.
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During the 15th century, the received learning was that an action on the case did not lie for mere inaction ("nonfeasance").Wootton v Brygeslay (1400); Watkin's Case (1425) By the beginning of this 16th century, this was no longer the case. Provided a plaintiff could show that the defendant was guilty of misfeasance, deceit, or the plaintiff had made a pre-payment, the plaintiff could bring assumpsit for nonfeasance. By the beginning of the 16th century lawyers recognised a distinct species of action on the case known as assumpsit, which had become the typical phrase in the pleadings.
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The Common Law Procedure Act 1852 abolished the common law forms of action in England and Wales. Furthermore, assumpsit as a form of action became obsolete in the United Kingdom after the passing of the Judicature Acts of 1873 and 1875. In the United States, assumpsit, like the other forms of action, became obsolete in the federal courts after the adoption of the Federal Rules of Civil Procedure in 1938. Thirty-five states have moved to rules similar to the FRCP (see Civil procedure in the United States), which have replaced the various forms of action with the civil action.
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Edward Coke was counsel for Slade, arguing that the King's Bench had the power to hear assumpsit actions, along with Laurence Tanfield, while Francis Bacon and John Doddridge represented Morley. The quality of legal argument was high; Bacon was a "skillful, subtle intellect" capable of distinguishing the precedent brought up by Coke, while Doddridge, a member of the Society of Antiquaries, knew the records even better than Coke did. Coke, rather than directly confronting opposing counsel, made a twofold argument; firstly, that the fact that the King's Bench had been allowed to hear assumpsit actions for so long meant that it was acceptable, based on institutional inertia, and second that, on the subject of assumpsit being used for breaches of promise, that the original agreement included an implied promise to make payment. The case continued for five years; at one point, the judges let the matter continue for three years because they could not reach a decision.
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Slade's Case effectively put an end to the use of debt sur contract, and with it wager of law. Of course, it was not possible to bring assumpsit where the proper action was debt sur obligation (that is, debt on a deed or bond).
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On 12 August 1831 Campbell then began court action against Milton for the arrears of rent. As the original lease agreement no longer existed Campbell sued Milton under an action of assumpsit (or breach of promise to pay) for use and occupation of Campbell's land.
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The legal fiction used was that by failing to pay after promising to do so, a defendant had committed deceit, and was liable to the plaintiff. The conservative Common Pleas, through the appellate court the Court of Exchequer Chamber, began to overrule decisions made by the King's Bench on assumpsit, causing friction between the courts. In Slade's Case, a case under assumpsit, which was brought between judges of the Common Pleas and King's Bench, was transferred to the Court of Exchequer Chamber where the King's Bench judges were allowed to vote. The case dragged on for five years, with the judgment finally being delivered in 1602 by the Chief Justice of the King's Bench, John Popham.
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But, in the circumstances prevailing in 1846, it is not difficult to > see that a plaintiff would necessarily be put to an election between the > real and fictitious promises. In cases of tort it is equally plain that > there had to be a choice between an action on a fictitious assumpsit > (waiving the tort) and seeking damages for the tort. 26\. The decision in > Walstab v Spottiswoode may also be seen as a consequence of two historical > threads. The first is the competition in the latter part of the sixteenth > century between the judges of the King's Bench and those of the Common Pleas > as to the relationship between debt and assumpsit .
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The Court of the King's Bench held that there was an implied understanding (i.e. implied assumpsit, or "assumption" of obligation) that a fee would be paid. Where a past benefit was conferred at the beneficiary's request, and where a reward would reasonably be expected, the promisor would be bound by his promise.
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The now-abolished forms of action cast a long shadow: a claim for money had and received evolved from the writ of indebitatus assumpsit, a legal fiction that the parties had an implied agreement that upon discharge for breach or frustration that the subject matter of the original agreement would be returned. An alternative form of action lay in debt. In Holmes v Hall (1677) 2 Mod 260, it was recognised that where concurrent claims existed and a claim in assumpsit indebitatus was available, the claim in assumpsit operated to exclude other claims. In the 'modern' language of Dutch v Warren (1720) 1 Stra 406, '[the defendant] has given the plaintiff an option to disaffirm the contract, and recover the consideration he was paid for it in the same manner as if it had never existed....but then the contract must be totally rescinded...;since otherwise, the contract is affirmed by the plaintiff's having received part of that equivalent for which he has paid his consideration, and it is then reduced to a mere question of damages proportionate to the extent to which it remains unperformed.
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Arris v Stukley(1677) 2 Mod. 2 60 > (86 ER 060) is an example. In that case, the defendant, who had been granted > by letters patent the office of comptroller of the customs at the port of > Exeter, continued to pretend title to that office after its termination and > grant to the plaintiff. The Court held that indebitatus assumpsit lay to > recover the profits received by the defendant after the grant of the office > to the plaintiff. In Holmes v Hall(1704) 6 Mod 161 (87 ER 918); Holt KB 36 > (90 ER 917) Holt CJ refused to nonsuit the plaintiff who sued on an > indebitatus assumpsit to recover moneys he paid as executor to the defendant > who held certain writings of the testator.
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West v. Barnes was the first case decided by the court. Collet originated as an assumpsit case in Pennsylvania state court, but eventually came to the federal Circuit Court where the Circuit Court ruled that Congress' power of naturalization was concurrent with the state's. Collet obtained a writ of error but dropped the case before reaching the Supreme Court.
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In the King's Bench, it was not necessary for the plaintiff to prove the subsequent promise. The Common Pleas disagreed. Matters came to a head in Slade's Case in 1602. The case effectively established that assumpsit could be used in lieu of debt: the law would imply a promise to pay the debt from the existence of the debt itself.
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The legal fiction used was that by failing to pay after promising to do so, a defendant had committed deceit, and was liable to the plaintiff.Simpson (2004) p.70 The conservative Common Pleas, through the appellate court the Court of Exchequer Chamber, began to overrule decisions made by the King's Bench on assumpsit, causing friction between the courts.Simpson (2004) p.
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The decision of the court was that even without registered title Campbell was the legal owner of the 120 acres, and that Milton was the permissive occupant. The action for assumpsit (or breach of promise to pay) for Milton's use and occupation of Campbell's land was therefore proved. Milton was ordered to pay to Campbell damages of £25 17s 4d, the arrears in the rent.
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This led to the general adoption of assumpsit – proceeding originally upon a fictitious averment of a promise by the defendant – as a means of recovering debts. Where a penalty was created by statute, it became a common form to insert a proviso that no wager of law was to be allowed in an action for the penalty. Wager of law was finally abolished in 1833 (3 & 4 William IV. c. 42).
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By that time, the change was purely procedural, but it also freed the substantive law from the old medieval forms of action. It permitted the development of broad concepts, such as liability in tort which could never have come about when confined by the old forms of action, such as trover. This served to rationalize the law. Just as forms of assumpsit replaced debt, so in the seventeenth century trover replaced detinue.
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Sprat v Agar is an early and landmark precedent and decision in third-party contract law, that is defeating privity of contract.William Nelson, An Abridgment of the Common Law: (R. Gosling, W. Mears, 1726 ) Volume 3. It was one of a number of early cases in the development of how the writ of assumpsit came to allow third parties with no direct involvement to a contract could achieve standing to enforce benefits from a contract.
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In contract law, certain binding promises are implied by law irrespective of the unwilling promisor's desire not be so bound. Thus, a husband "constructively" promises to pay for his wife's necessities or often for medical care that is given him. The common law entertained a legal fiction, indebitatus assumpsit, that a person owing a debt promised to pay it, so that he could be sued on that imagined promise. See Lionel D Smith, et al.
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However, many states continue to recognize assumpsit as a common law or statutory cause of action or allow the use of the old "common counts" as causes of action. For example, California has a special "common counts" cause of action form (to be attached to an optional form complaint) based directly on the old common counts that were pleaded in assumpsit.Form PLD-C-001(2), Cause of Action-Common Counts, Judicial Council of California (Rev. Jan. 1, 2009).
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Then the widow married the defendant, J.S. Mr Bret brought an action for the £6 13s 4d for tabling in the two years following. The report shows the counsel for JS and the wife, Warburton, argued (1) this was an entire contract by the first husband for the entire year and it could not be apportioned (2) natural affection is not a sufficient ground for an assumpsit without quid pro quo (3) the contract should have been pleaded as an action for debt.
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Slade's Case (or Slade v. Morley) was a case in English contract law that ran from 1596 to 1602. Under the medieval common law, claims seeking the repayment of a debt or other matters could only be pursued through a writ of debt in the Court of Common Pleas, a problematic and archaic process. By 1558 the lawyers had succeeded in creating another method, enforced by the Court of King's Bench, through the action of assumpsit, which was technically for deceit.
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In short, the plaintiff would separate the existence of the debt (which generated an action of debt sur contract) from a promise to pay the debt (which would generate an assumpsit for nonfeasance). This form of pleading gave rise to the name of the action: indebitatus assumpsit.The Latin phrase means "being indebted, he promised," or, more literally, "he undertook" or "he assumed the duty [to pay]." The practice of the King's Bench and the Court of Common Pleas differed during the course of the 16th century.
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At common law not all promises were enforceable. One way in which a promise is enforceable is the modern law of contract, which arose from the old action of assumpsit, and concepts of motive and reliance. In Australia, the bargain theory prevails, under which the exchange of promises, referred to in the Latin term quid pro quo, is an essential element. A promise made under seal was enforceable under the old action on the covenant, which has developed into the modern law in relation to deeds.. Promises may now also be enforceable as negligent mis-statement,.
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45 The troubles during this period are best illustrated by Slade's Case. Under the medieval common law, claims seeking the repayment of a debt or other matters could only be pursued through a writ of debt in the Common Pleas, a problematic and archaic process. By 1558 the lawyers had succeeded in creating another method, enforced by the Court of King's Bench, through the action of assumpsit, which was technically for deceit. The legal fiction used was that by failing to pay after promising to do so, a defendant had committed deceit, and was liable to the plaintiff.
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An action for money had and received to the plaintiff's use is the name for a common law claim derived from the form of action known as indebitatus assumpsit. The action enabled one person to recover money which has been received by another: for example, where a plaintiff paid money to the defendant while labouring under a mistake of fact or where there was a total failure of consideration. The action was a personal action only available in respect of money, rather than other benefits. Where the benefit received by the defendant was services or goods, the appropriate action was a quantum meruit or a quantum valebant, respectively.
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In 1585 a new form of the Court of Exchequer Chamber was set up, an appellate court where the Common Pleas judges held a majority, and regularly began to reverse King's Bench judgments which were based on assumpsit. This, and the conflict between the King's Bench and the Common Pleas as a whole, was problematic; a plaintiff at assizes could not be sure which sort of judge his case would come before, lending uncertainty to the law. Boyer suggests that, in this environment, the Chief Justice of the King's Bench John Popham deliberately provoked the Common Pleas to resolve the matter, and did so through Slade's Case.
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John Slade was a grain merchant, who claimed that Humphrey Morley had agreed to buy a crop of wheat and rye from him, paying £16, and had reneged on the agreement. He brought the case before the Assizes in 1596, where it was heard by two judges; one of the Common Pleas, and one of the King's Bench. It was heard under assumpsit, and the jury found that Morley indeed owed Slade money. Before a judgment could be issued, Popham had the case transferred to an older version of the Court of Exchequer Chamber, which, sitting in Serjeant's Inn, allowed the King's Bench judges to sit.
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Wager of law survived to recent centuries and in many jurisdictions it has been abolished by statute. It was abolished in New South Wales in 1841 by the Advancement of Justice Act 1841 (both Victoria and Queensland were still part of New South Wales at this time). This was re-enacted after separation of Queensland from New South Wales in the Queensland Common Law Practice Act 1867, but was strictly unnecessary, given its earlier abolition in 1841 which makes direct reference to the abolition of wager of law. No wager of law was allowed in assumpsit, even though the cause of action were a simple debt.
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12 As a longer term and more significant development, the Bill of Middlesex was one of several revolutionary developments by the King's Bench met with a conservative reaction from the Common Pleas, fearful of losing its own caseload. The troubles during this period are best illustrated by Slade's Case. Under the medieval common law, claims seeking the repayment of a debt or other matters could only be pursued through a writ of debt in the Common Pleas, a problematic and archaic process. By 1558 the lawyers had succeeded in creating another method, enforced by the Court of King's Bench, through the action of assumpsit, which was technically for deceit.
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By 1558 the lawyers had succeeded, with the Court of King's Bench agreeing to hear cases under this piece of legal fiction. The judges of the Common Pleas, however, a more traditional group, rejected this argument and only accepted cases where an actual promise had been made in addition to the contract. The action of assumpsit had several advantages over a writ of debt; the plaintiff could count on always having a jury, while in writs of debt the defendant could rely on wager of law, where he produced twelve people to swear he did not owe the plaintiff money and had the case dismissed. In addition, it worked for executory agreements, not just normal contracts.
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The impact of the case was immediate and overwhelming. Ibbetson considers Slade's Case to be a "watershed" moment, in which the archaic and conservative form of law was overwritten by a modern, more efficient method. Assumpsit became the dominant form of contract cases, with the door "opened wide" to plaintiffs; Boyer suggests this was perhaps "too wide". In his Commentaries on the Laws of England, William Blackstone explained that this was the reason why the Statute of Frauds was subsequently passed in 1677: The case is particularly notable as an example of judicial legislation, with the judges significantly modernising the law and moving it forward in a way Parliament had not considered.
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The critical decision in > the resolution of the conflict was Slade's Case.(1602) 4 Co Rep 92b (76 ER > 1074); also reported as Slade v. Morley Yelv 21 (80 ER 15), MooKB 433 (72 ER > 677) While the precise contemporary import of the decision is a matter of > controversy,See Lucke, "Slade's Case and the Origin of the Common Counts", > (1964) 81 Law Quarterly Review 422 and 539, (1966) 82 Law Quarterly Review > 81; Baker, "New Light on Slade's Case", (1971) Cambridge Law Journal 51 and > 213; . it was taken in the seventeenth century as deciding that indebitatus > assumpsit lay as well as debt to recover sums due under a contract in the > absence of an express subsequent promise to pay.
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Under the medieval common law, there was only one way to resolve a dispute seeking the repayment of money or other contract matters; a writ of debt, which only the Court of Common Pleas could hear. This was archaic, did not work against the executors of a will and involved precise pleading; a minor flaw in the documents put to the court could see the case thrown out. By the middle of the 16th century lawyers had attempted to devise an alternative using the action of assumpsit, which was technically a type of trespass due to deceit. The argument was based on the idea that there was an inherent promise in a contract to pay the money, and that by failing to pay the defendant had deceived the plaintiff.
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John Popham, the Chief Justice of the King's Bench who brought the Common Pleas and King's Bench into conflict over assumpsit While these reforms succeeded in forming an equilibrium between the old common law courts and the new courts, they were viewed with suspicion by the Common Pleas, who became highly reactionary to the changes the King's Bench attempted to introduce. While the King's Bench was more revolutionary, the Common Pleas became increasingly conservative in its attempts to avoid ceding cases. The disparity between the reformist King's Bench and conservative Common Pleas was exacerbated by the fact that the three Common Pleas prothonotaries could not agree on how to cut costs, leaving the court both expensive and of limited malleability while the King's Bench became faster, cheaper and more varied in its jurisdiction.Baker (2002) p.
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A volunteer is defined in equity as one who has not offered consideration for a benefit they have received or expect to receive. For example, if a person A expects from past conversations and friendship to receive property under any will of person B, but person B dies before writing this into their will, person A, having not made any contribution to person B, will not be able to seek equity's aid.. This maxim is very important in restitution. Restitution developed as a series of writs called special assumpsit, which were later additions in the courts of law, and were more flexible tools of recovery, based on equity. Restitution could provide means of recovery when people bestowed benefits on one another (such as giving money or providing services) according to contracts that would have been legally unenforceable.
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Sydney Monitor, 5/10/1831: :SUPREME COURT - CIVIL SIDE :SEPTEMBER 30 - Before Mr. Justice DOWLING, and Messrs. McLaren and Ross, J, P.'s, Assessors. :Campbell v Milsom - This was an action of assumpsit (breach of a promise to pay), to recover the sum of £25 17 4d, for rent due from the defendant for the use and occupation of a certain farm situate on the North Shore, leased by the plaintiff to defendant for a term of years. It appeared in evidence that the defendant leased a farm of 120 acres at the North Shore, from the plaintiff his former employer, as a matter of favour from the plaintiff, at an under rent of £10 per annum, for a term of seven years originally, and which was subsequently extended three years for the purpose of growing vegetables, &c.
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Initially, the courts held that an action for trover would lie for blacks, as if they were chattels, but this was reasoned on the grounds that they were infidels rather than slaves, and lacked the rights enjoyed by ChristiansSee Butts v Penny (1677) 2 Lev 201, 3 Keb 785 - an action was brought to recover possession of 100 slaves. The court held that slavery was legal in England in relation to infidels and that an action for trover would lie; see also Gelly v Cleve (1694) 1 Ld Raym 147 (reasoning which would later find echoes in the U.S. case of Dred Scott v. Sandford 60 U.S. (19 How.) 393 (1857)) but Judge Holt was to later reject this analysis,Chamberlain v Harvey (1697) 1 Ld Raym 146; Smith v Gould (1705-07) 2 Salk 666 and also denied the possibility of bringing an assumpsit on the sale of a black person in England: "as soon as a negro comes to England he is free; one may be a villein in England, but not a slave."Smith v Brown (1702) 2 Salk 666 However, this comment was construed as more of an admonition against careless pleading rather than a reproach to slave dealers.
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