Coward v MIB [1] was a 1963 Court of Appeal decision on intention to create legal relations, and on the liability of the Motor Insurers Bureau when a passenger in a vehicle is killed or injured through the driver's negligence.
The Court of Appeal held there was no contract of hire or reward as it was a social and domestic agreement without intention to create legal relations, and that the widow was not entitled to compensation.
In Connell v Motor Insurers Bureau [3] Lord Denning, MR, sitting in the Court of Appeal declared that he was "not happy with the decision in Coward", adding that "when a man gives another a lift in return for money there is a contract, albeit informal".
Denning refused to follow Coward and declared that a car driver who gave friends a lift in return for cash or other valuable consideration was indeed acting "for hire or reward".
Strictly speaking, Denning was in breach of the rule that the Court of Appeal is bound by its own earlier decisions; but in Albert v Motor Insurers Bureau [4] the House of Lords in 1971 approved the Connell judgment in preference to that in Coward.