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.