Robinson v Balmain New Ferry Co Ltd [1910] AC 295

Material Facts:

The plaintiff went onto the defendant’s wharf to enable him take a boat. At the entrance of the wharf was the notice "…A fare of one penny must be paid on entering or leaving the wharf. No exception will be made to this rule, whether the passenger has travelled by the ferry or not." The plaintiff paid a penny and went onto the wharf. On exiting, the plaintiff refused to pay the penny for leaving the wharf and the defendant prevented him from leaving the wharf till he paid the penny. The plaintiff eventually managed to leave the wharf and brought an action against the defendant for false imprisonment.

Issue:

Whether or not the defendant falsely imprisoned the plaintiff.

Holding:

The plaintiff was not falsely imprisoned.

Ratio Decidendi:

That the notice at the entrance of the wharf provided the conditions under which a person may leave the wharf, which is by the payment of a penny. The plaintiff entered the wharf with this knowledge and can be prevented from leaving the wharf if he fails to fulfil the contractual obligation reasonably imposed on him. The court reasoned that when a person enters an agreement that stipulates the terms of entry or exit from a premises (the wharf in this instance), it does not amount to false imprisonment if he is prevented from exiting the premises contrary to the terms of the agreement.