Liverpool City Council v Irwin [1976] UKHL 1 is a leading English contract law case concerning the basis on which courts may imply terms into contracts; in particular in relation to all types of tenancies (including leases of land), a term may be implied if required for a particular relationship, such as for the landlord to keep the stairwells clear in a tower block.

The House of Lords held that there was an implied term that the landlord should take care of the common parts of a building.

The tenants also had a duty of reasonable care, and so they were not entitled to withhold rent on the facts.

Lord Wilberforce held it was a necessary term of living on an estate that landlords keep stairwells in order.

Applying the business efficacy or the officious bystander test would not result in the term’s implication, but asking what the relationship required would.