Glasbrook Bros Ltd v Glamorgan County Council – Case Summary

Glasbrook Bros Ltd v Glamorgan County Council

House of Lords

Citations: [1925] AC 270.


A colliery manager’s employees were going on strike. The manager applied for police protection for the duration of the strike. He argued that he needed the police to send officers to remain in the colliery. The police superintendent thought that a mobile force was adequate. He therefore refused to send standing officers unless the manager paid. This was a common practice at the time, and there were some statutory regulations relating to the practice.

There was later a dispute as to whether the arrangement between the manager and the superintendent was a binding contract. In particularly, the parties disputed whether the police had provided consideration. The manager argued that the police provided no consideration, because they were already under a duty to provide officers. He also argued that any agreement would be void for public policy reasons.

  1. Did the police provide consideration for the manager’s agreement to pay for standing officers?
  2. Was enforcing the agreement against public policy?

The House of Lords argued that the agreement was a binding contract. The police were only duty-bound to provide sufficient protection to life and property. They could provide consideration by going above and beyond this duty.

In this case, the superintendent had gone beyond his duty by offering a service which he reasonably did not think necessary to sufficiently protect the colliery. He therefore provided good consideration. Enforcing this contract was not against public policy.

This Case is Authority For…

A person cannot rely on an existing public duty as consideration. However, if they go beyond the scope of that duty, this counts as good consideration.


A contract is unlikely to be void for public policy reasons where the practice is regulated by statute.

Lord Carson dissented. He thought it was illegal for the police to provide their services for money in emergency situations. This was because anyone entering into such a contract was likely to be under duress – like the manager in this case, who feared for his property. Based on this, he considered the superintendent to have provided no consideration. Lord Blanesburgh also dissented, arguing that on the facts the police had done no more than their duty. He thought that the situation was such that the manager was right to think that a standing force was necessary.