ABSTRACT
The legal position here mirrors that of retail displays (to which it is closely related). Indeed, in Partridge v Crittenden,22 Lord Parker CJ stated that he came to this conclusion ‘with less reluctance’ than in retail display cases, since ‘when one is dealing with advertisements and circulars, unless they indeed come from manufacturers, there is business sense in their being construed as invitations to treat, and not offers for sale ...’23 It should, of course, be noted that, even here there are exceptions, as the Carlill case and other ‘offer of reward’ cases demonstrate. Lord Parker also indicates another possibility with his rather cryptic references to manufacturers’ advertisements (is it clear why the position of manufacturers should be different?).
