National Westminster Bank plc v Morgan [1985] UKHL 2 is a judicial decision of the House of Lords relating to English contract law and the doctrine of undue influence.

The case is most well known for the comments of Lord Scarman about the supposed requirement of "manifest disadvantage" to set aside a contract for undue influence.

The judge found that the bank was not seeking any advantage other than to provide on normal commercial terms but at extremely short notice the bridging finance necessary to secure their home.

one party over the other.Dunn LJ held that manifest disadvantage was not a necessary ingredient of presumed undue influence, giving the example of a solicitor buying a client’s house.

And even in the field of contract I question whether there is any need in the modern law to erect a general principle of relief against inequality of bargaining power.

I doubt whether the courts should assume the burden of formulating further restrictions.The case was often cited as proposition that the House of Lords required "manifest disadvantage" in order to set aside a transaction for undue influence.

Although Morgan has never been overruled or doubted, the law in this area has been largely superseded by the decision in Royal Bank of Scotland plc v Etridge (No 2) [2001] UKHL 44 (11 October 2001).