Welch v Jess [1976] NZ recent Law 185 is a reported precedent case in New Zealand on intention to create legal relations in the law of contract.

Jess and his friend Welch entered a fishing contest on Ninety Mile Beach.

Jess subsequently won $6,000 but later refused to share the prize money, claiming that it was merely a social agreement not intended to be enforced the parties.

For an agreement to become a contract, there must be intention to create legal relations.

[3] Two judicial devices aid a court to decide whether there is intent: The objective test was established in Carlill v Carbolic Smoke Ball Co, where it was held that any reasonable man who read an advertisement that said the advertiser had "deposited £1000 in the Alliance Bank to show our sincerity in the matter" would deem that there was intention to create legally relations (even though, subjectively, the advertiser was a rogue who had no intention of honouring the agreement).