_Contract_Lawcards by_Routledge-Cavendish_4th_Ed

The traditional view, however, was applied by the House of
Lords in Gibson v Manchester City Council (1979).
Lord Diplock did recognise that there may be some
‘exceptional contracts which do not fit easily into an analysis
of offer and acceptance’, for example, a multi-partite contract
as in Clarke v Dunraven (1897), but he stressed that in most
contracts the ‘conventional’ approach of seeking an offer and
an acceptance of that offer must be adhered to.