古罗马有句法谚：“合意创立法律”，那么，如果男生许诺女生“爱你一万年”，然而却没有做到，女生可不可以据此追责？再如果说，男人向女人信誓旦旦并立字为据，说“如果将来出轨，就甘愿净身出户”，结果一语成谶，婚后真的出轨，那么，女人是否可以据此誓言来寻求法律支持？
尽管“合意创立法律”，但也并不是所有合意行为都能被法律规制和调整。如果一个人所作出的每一个允诺都具有法律拘束力的话, 这个世界将变成非常不安全的地方。[1] 因此，甄别哪些合意行为才能构成法律行为，进而具有法律拘束力就变成是不管英美法系还是普通法系都面临的一个课题，今天我们就看一下被誉为“合同强制力的标志性判例”的判例，1919年的Balfour v Balfour案：
Facts（事实）
The Plaintiff(Mrs Balfour) and the Defendant(Mr Balfour) were a married couple. The Defendant husband and the Plaintiff wife lived in Ceylon where the Defendant worked. In 1915, while the Defendant was on leave, the couple returned to England. When it was time to return to Ceylon, the Plaintiff was advised not to return because she had developed a disease rheumatic arthritis, the jungle climate would be detrimental to her health. Prior to the Defendant returning, he promised to send the Plaintiff 30 per month as support until she came back to Ceylon. The Defendant continued to send the money to the Plaintiff for some time. Then the parties’ relationship deteriorated and the parties began living apart and subsequently the Defendant stopped sending money to his wife. The Plaintiff brings suit to enforce the Defendant’s promise to pay her 30 per month. The lower court found the parties’ agreement constituted a contract.
Balfour夫妇于1900年8月结婚。丈夫( 被告) 是一位土木工程师,担任锡兰( 现称斯里兰卡) 的政府任水利部总监。婚后夫妻一直在锡兰生活了15年。1915年11月,他们到英国度假。1916年8月8日,丈夫假满要回锡兰继续工作,而妻子因患风湿性关节炎,遵医嘱留在英国。因为锡兰的丛林气候将不利于Balfour太太的健康。在被告离开之前,留给妻子一张24英镑的支票,作为当月的生活费,并口头承诺每月给妻子30英镑直到她回到锡兰夫妻团聚为止。随后被告回到锡兰,夫妻逐渐疏远, 1918年3月,夫妻离婚,妻子( 原告) 在获得法定抚养费后起诉被告违约,要求被告支付剩余的每月30英镑的生活费。
本案的一审法院支持了Balfour太太的诉请，签发了离婚暂准令 (Decree Nisi)[2]，Sargant法官根据丈夫负有抚养妻子的义务而判决支持原告的诉求。Balfour先生不服，于是上诉到上诉法院，上诉法院的三位法官（Warrington、Duck、Atkin ）则一致认定本案不存在具有法律强制力的协议。
Warrington法官认为:
如果我们认定本案中存在一个有法律拘束力的合同的话, 我们将必须认可以下推定, 一个妻子在生活中涉及所有的或多或少的琐碎的事情, 按照丈夫的要求作出一项允诺, 此项允诺即可得到法律的强制执行。
The matter really reduces itself to an absurdity when one considers it, because if we were to hold that there was a contract in this case we should have to hold that with regard to all the more or less trivial concerns of life where a wife, at the request of her husband, makes a promise to him, that is a promise which can be enforced in law.
我想说的是此处不存在这样的合同。本案中的Balfour先生和Balfour太太从来没有创设一项具有法律强制力的“交易”的意图。丈夫明确表达愿意支付的意图, 并且他承诺履行它, 只要他仍然是Balfour太太的丈夫在道义上就有责任继续履行。另一方面就妻子而言, 就我能理解的来说, 完全没有给予任何“交换”。
All I can say is that there is no such contract here. These two people never intended to make a bargain which could be enforced in law. The husband expressed his intention to make this payment, and he promised to make it, and was bound in honour to continue it so long as he was in a position to do so. The wife on the other hand, so far as I can see, made no bargain at all. That is in my opinion sufficient to dispose of the case.
Duck法官则认为:
本案中的分居协议自其成立时起就没有相互的约因。本案甚至完全不存在分居协议。
An agreement for separation when it is established does involve mutual considerations. But in this case there was no separation agreement at all.
当事人是丈夫和妻子, 考虑所有的情况, 在法律的观点上, 涉及协议的关系意图。不可能说存在夫妻关系的允诺就具有交换性, 它们还必须是合同本质上的允诺。在当事人涉及家庭关系的场合, 要确定一个合同, 要求比仅仅是相互允诺还多一些东西。即要求任何一方当事人能找到产生法律关系的债务以取代之前基于允诺而找到的合同。
The parties were husband and wife, and subject to all the conditions, in point of law, involved in that relationship. It is impossible to say that where the relationship of husband and wife exists, and promises are exchanged, they must be deemed to be promises of a contractual nature. In order to establish a contract there ought to be something more than mere mutual promises having regard to the domestic relations of the parties. It is required that the obligations arising out of that relationship shall be displaced before either of the parties can found a contract upon such promise.
因此, 我认为, 在原则这点上, 本案不存在诉求的基础, 妻子同意从英国回到丈夫住处或者是丈夫允诺妻子, 都不充足构成依据合同诉讼的约因。
I think, therefore, that in point of principle there is no foundation for the claim which is made here, and I am satisfied that there was no consideration moving from the wife to the husband or promise by the husband to the wife which was sufficient to sustain this action founded on contract.
Atkin法官的观点则更加清晰明确：本案中丈夫的允诺没有“创设法律关系的意图”,因为在夫妻之间的家庭协议,主张协议具有法律拘束力的一方应承担举证责任,以推翻日常家庭协议没有“创设法律关系的意图”的推定。而原告提供的口头证据不足以说明这点。最终,上诉法院驳回了原告的诉讼请求，支持了被告的上诉：
Nevertheless they are not contracts, and they are not contracts because the parties did not intend that they should be attended by legal consequences.
这类夫妻协议，或者说大部分这类协议，根本不能形成合同（即使像其他当事人之间一样存在对价，它们也不是合同）因为当事人之间并不打算受到法律后果的约束。
All I can say is that the small Courts of this country would have to be multiplied one hundredfold if thwww.58yuanyou.comese arrangements were held to result in legal obligations.
我想说，还有另外一个理由，那就是，如果这样的协议都被界定为合同得到法庭支持的话，势必会导致更多的人凭借此类案由诉诸法庭，那么小额诉讼法庭案件将会成百上千地增长。
They are not sued noon, not because the parties are reluctant to enforce their legal rights when the agreement is broken, but because the parties, in the inception of the arrangement, never intended that they should be sued upon.
现在，当事人不去因为这样的事情提起诉讼，不是因为他们不愿意在对方违约时通过法律来维权，而是因为当事人在订立合同时，就没有想过这件事会走到法庭。
Agreements such as these are outside the realm of contracts altogether. The common law does not regulate the form of agreements between spouses.
这类协议已经超越了合同法的调整范围，在家庭的大门之内，是一个不受法院干预的独立王国。
对于本案，英国家庭法上的创始人之一Otto Kahn Freund教授在1952年指出：这个案子是一个非常明智的判决，他用生活的现实，决定了法律的标准。
此案之后，英美法实践中确立了“对家庭成员之间的协议,英美判例实践推定其无创设法律关系的意图,故不成立合同,没有法律拘束力”的规则，并在1969年的Jones v. Padavatton（母女房产协议）案中得到了适用，法官以“涉及房产的协议属于母亲对女儿经济支助作出的适应形势的安排,并不是一个具有法律拘束力的合同。”为由，驳回了女儿的起诉。
然而这个案件也引发了我们的思考，是不是所有夫妻间的协议都不具有法律拘束力呢？夫妻为了分居而达成的协议或者在决定分句后达成的协议，以及婚前的许诺，是不是也不具有约束力呢？前述两个问题，丹宁勋爵在其对1970年的Merritt v. Merritt案的判词中给出了答案，他认为Merritt夫妇基于关系破灭而对相关事务的安排所订立的合同，可以推定该协议具有比一般的家庭协议的更为深层次的法律意义，应该受法律约束。
根据英美法裁判规则，一般而言，家庭成员之间协议因推定无创设法律关系的意图而不具有法律拘束力。但是，如果有证据证明家人之间订立的协议确实具有创设法律关系的意图,并且经过审慎思考,那么该协议就有可能具有法律拘束力。一般而言，以下三种情况下，即便是家人之间订立的协议，也会被认为是有法律拘束力的：
(1) 夫妻关系恶化,感情破裂之时对未来生活的涉及夫妻财产或者家庭财产的安排的协议。
(2) 家庭成员之间订立的分家析产协议或者是家庭成员之间订立的财产协议。
(3) 受允诺人基于对允诺的信赖付出“对价”。诸如受允诺人基于信赖允诺的法律效力而做出符合允诺人期待的行为。
其中第三条原则还被适用到商事案件审判中，如果在一份商业合同中当事人明确约定这是一份君子协议，他们无在未来收到该份协议法律拘束的意图，那么在纠纷发生时，他们就无法通过法律途径得到救济，这在1932年的Rose & Frank Co. v. JR Crompton & Bros Ltd.案中得到了验证和支持。
附：Balfour v Balfour案判决原文：
2 K.B. 571
BALFOUR
v.
BALFOUR.
King's Bench Division.
June 24-25, 1919.
Husband and Wife—Contract—Temporary Separation—Allowance for Maintenance of Wife—Domestic Arrangement—No resulting Contract.
The plaintiff sued the defendant (her husband) for money due under an alleged verbal agreement, whereby he undertook to allow her 30 a month in consideration of her agreeing to support herself without calling upon him tor any further maintenance. The parties were married in 1900. The husband was resident in Ceylon, where he held a Government appointment. The plaintiff accompanied him to Ceylon, but in 1915 they returned to England, he being on leave. In 1916 he went back to Ceylon, leaving her in England, where she had to remain temporarily under medical advice. The plaintiff alleged that the defendant before returning to Ceylon entered into the above agreement. The parties remaining apart, the plaintiff subsequently obtained a decree nisi for restitution of conjugal rights, and an order for alimony:
Held, that the alleged agreement did not constitute a legal contract, but was only an ordinary domestic arrangement which could not be sued upon. Mutual promises made in the ordinary domestic relationship of husband and wife do not of necessity give cause for action on a contract.
Decision of Sargant J. reversed.
APPEAL from a decision of Sargant J., sitting as an additional judge of the King's Bench Division.
The plaintiff sued the defendant (her husband) for money which she claimed to be due in respect of an agreed allowance of 30 a month. The alleged agreement was entered into under the following circumstances. The parties were married in August, 1900. The husband, a civil engineer, had a post under the Government of Ceylon as Director of Irrigation, and after the marriage he and his wife went to Ceylon, and lived there together until the, year 1915, except that in 1906 they paid a short visit to this country, and in 1908 the wife came to England in order to undergo an operation, after which she returned to Ceylon. In November, 1915, she came to this country with her husband, who was on leave. They remained in England until August, 1916, when the husband's leave was up and he had to return. The wife however on the doctor's advice remained in England. On [572] August 8, 1916, the husband being about to sail, the alleged parol agreement sued upon was made. The plaintiff, as appeared from the judge's note, gave the following evidence of what took place: "In August, 1916,defendant's leave was up. I was suffering from rheumatic arthritis. The doctor advised my staying in England for some months, not to go out till November 4. On August 8 my husband sailed. He gave me a cheque from 8th to 31st for 24, and promised to give me 30 per month till I returned." Later on she said: "My husband and I wrote the figures together on August 8; 34 shown. Afterwards he said 30." In cross-examination she said that they had not agreed to live apart until subsequent differences arose between them, and that the agreement of August, 1916, was one which might be made by a couple in amity. Her husband in consultation with her assessed her needs, and said he would send 30 per month for her maintenance. She further said that she then understood that the defendant would be returning to England in a few months, but that he afterwards wrote to her suggesting that they had better remain apart. In March, 1918, she commenced proceedings for restitution of conjugal rights, and on July 30 she obtained a decree nisi. On December 16, 1918, she obtained an order for alimony.
Sargant J. held that the husband was under an obligation to support his wife, and the parties had contracted that the extent of that obligation should be defined in terms of so much a month. The consent of the wife to that arrangement was a sufficient consideration to constitute a contract which could be sued upon.
He accordingly, gave judgment for the plaintiff.
The husband appealed.
Barrington-Ward K.C. and Du Parcq for the appellant.
Where husband and wife are only temporarily living apart an agreement like that ill the present case confers no contractual rights. There was no agreement for a separation. The agreement here was a purely domestic arrangement intended to take effect until the wife should rejoin her husband. It cannot be regarded as a binding contract. The wife gave no consideration for the promise.
On the evidence it is submitted that this was a temporary domestic arrangement caused by the absence of the husband abroad, and was not intended to have a contractual operation.
Hawke K.C. and Tebbs for the respondent.
Where a husband and wife are living together the wife is as capable of contracting with her husband that he shall give her a particular sum as she is of contracting with any other person.
Where husband and wife separate by mutual consent, the wife making her own terms as to her income and that income proves insufficient for her support, the wife has no authority to pledge her husband's credit: Eastland v. Burchell.
[DUKE L.J. That may be because they must be taken to have agreed not to live as husband and wife.]
Living apart is a question of fact. If the parties live apart by mutual consent the right of the wife to pledge her husband's credit arises. If, however, instead of doing so she agrees to give up that right and to accept an allowance instead, she is entitled to sue for it.
The agency of the wife arises either where the husband leaves her wrongfully, or where the parties are by mutual consent living apart.
In Lush on Husband and Wife, 3rd ed., p. 404, it is stated that: "If the wife is living apart from her husband either (a) on account of the husband's misconduct, the wife being left without adequate means; (b) or by mutual consent; and the husband has agreed to make her an allowance, and neglects to pay it, the law gives her an absolute authority to pledge his credit for suitable necessaries."
[DUKE L.J. Are not those cases where the parties are matrimonially separated?]
[WARRINGTON L.J. referred to Lush on Husband and Wife, 3rd ed., p. 386.]
The agency arises where there is a separation in fact. The [574] consideration for the promise by the husband to pay the allowance was that she gave up her right to pledge his credit.
[DUKE L.J. The husband has a right to withdraw the authority to pledge his credit. The wife's consent, therefore, cannot be treated as consideration to support such a contract as this.]
Where a husband leaves his wife in England and goes abroad it is no longer at his will that she shall have authority to pledge his credit. If there be a separation in fact (except for the wife's guilt) the agency of necessity arises. The parties here intended to enter into a binding contract.
WARRINGTON L.J. (after stating the facts). Those being the facts we have to say whether there is a legal contract between the parties, in other words, whether what took place between them was in the domain of a contract or whether it was merely a domestic arrangement such as may be made every day between a husband and wife who are living together in friendly intercourse. It may be, and I do not for a moment say that it is not, possible for such a contract as is alleged in the present case to be made between husband and wife. The question is whether such a contract was made. That can only be determined either by proving that it was made in express twww.58yuanyou.comerms, or that there is a necessary implication from the circumstances of the parties, and the transaction generally, that such a contract was made. It is quite plain that no such contract was made in express terms, and there was no bargain on the part of the wife at all. All that took place was this: The husband and wife met in a friendly way and discussed what would be necessary for her support while she was detained in England, the husband being in Ceylon, and they came to the conclusion that 30 a month would be about right, but there is no evidence of any express bargain by the wife that she would in all the circumstances, treat that as in satisfaction of the obligation of the husband to maintain her. Can we find a contract from the position of the parties? It seems to me it is quite impossible. If we were to imply such a contract in this case we should be implying on the part of the wife that whatever happened and whatever might be the change of circumstances while the husband was away she should be content with this 30 a month, and bind herself by an obligation in law not to require him to pay anything more; and on the other hand we should be implying on the part of the husband a bargain to pay 30 a month for some indefinite period whatever might be his circumstances. Then again it seems to me that it would be impossible to make any such implication. The matter really reduces itself to an absurdity when one considers it, because if we were to hold that there was a contract in this case we should have to hold that with regard to all the more or less trivial concerns of life where a wife, at the request of her husband, makes a promise to him, that is a promise which can be enforced in law. All I can say is that there is no such contract here. These two people never intended to make a bargain which could be enforced in law. The husband expressed his intention to make this payment, and he promised to make it, and was bound in honour to continue it so long as he was in a position to do so. The wife on the other hand, so far as I can see, made no bargain at all. That is in my opinion sufficient to dispose of the case.
It is unnecessary to consider whether if the husband failed to make the payments the wife could pledge his credit or whether if he failed to make the payments she could have made some other arrangements. The only question we have to consider is whether the wife has made out a contract which she has set out to do. In my opinion she has not.
I think the judgment of Sargant J. cannot stand, the appeal ought to be allowed and judgment ought to be entered for the defendant.
DUKE L.J. I agree. This is in some respects an important case, and as we differ from the judgment of the Court below I propose to state concisely my views and the grounds which have led me to the conclusion at which I have arrived. Substantially the question is whether the promise of the husband to the wife that while she is living absent from him he will make her a periodical allowance involves in law a consideration on the part of the wife sufficient to convert that promise into a binding agreement. In my opinion it does not. I do not dissent, as at present advised, from the proposition that the spouses in this case might have made an agreement which would have given the plaintiff a cause of action, and I am inclined to think that the promise of the wife in respect of her separate estate could have founded an action in contract within the principles of the Married Women's Property Act, 1882. But we have to see whether here is evidence of any such exchange of promises as would make the promise of the husband the basis of an agreement. It was strongly urged by Mr. Hawke that the promise being absolute in form ought to be construed as one of the mutual promises which make an agreement. It was said that a promise and an implied undertaking between strangers, such as the promise and implied undertaking alleged in this case would have founded an action on contract. That may be so, but it is impossible to disregard in this case what was the basis of the whole communications between the parties, under which the alleged contract is said to have been formed. The basis of their communications was their relationship of husband and wife, a relationship which creates certain obligations, but not that which is here put in suit. There was a discussion between the parties while they were absent from one another, whether they should agree upon a separation. In the Court below the plaintiff conceded that down to the time of her suing in the Divorce Division there was no separation, and that the period of absence was a p原由网eriod of absence as between husband and wife living in amity. An agreement for separation when it is established does involve mutual considerations.
That was why in Eastland v. Burchell the agreement for separation was found by the learned judge to have been of decisive consequence. But in this case there was no separation agreement at all. The parties were husband and wife, and subject to all the conditions, in point of law, involved in that relationship. It is impossible to say that where the relationship of husband and wife exists, and promises are exchanged, they must be deemed to be promises of a contractual nature. In order to establish a contract there ought to be something more than mere mutual promises having regard to the domestic relations of the parties. It is required that the obligations arising out of that relationship shall be displaced before either of the parties can found a contract upon such promises. The formula which was stated in this case to support the claim of the lady was this: In consideration that you will agree to give me 30 a month I will agree to forego my right to pledge your credit. In the judgment of the majority of the Court of Common Pleas in Jolly v. Rees, which was affirmed in the decision of Debenham v. Mellon Erle C.J. states this proposition: "But taking the law to be, that the power of the wife to charge her husband is in the capacity of his agent, it is a solecism in reasoning to say that she derives her authority from his will, and at the same time to say that the relation of wife creates the authority against his will, by a presumptio juris et de jure from marriage." What is said on the part of the wife in this case is that her arrangement with her husband that she should assent to that which was in his discretion to do or not to do was the consideration moving from her to her husband. The giving up of that which was not a right was not a consideration. The proposition that the mutual promises made in. the ordinary domestic relationship of husband and wife of necessity give cause for action on a contract seems to me to go to the very root of the relationship, and to be a possible fruitful source of dissension and quarrelling. I cannot see that any benefit would result from it to either of the parties, but on the other hand it would lead to unlimited litigation in a relationship which should be obviously as far as possible protected from possibilities of that kind. I think, therefore, that in point of principle there is no foundation for the claim which is made here, and I am satisfied that there was no consideration moving from the wife to the husband or promise by the husband to the wife which was sufficient to sustain this action founded on contract. I think, therefore, that the appeal must be allowed.
ATKIN, L.J. The defence to this action on the alleged contract is that the defendant, the husband, entered into no contract with his wife, and for the determination of that it is necessary to remember that there are agreements between parties which do not result in contracts within the meaning of that term in our law. The ordinary example is where two parties agree to take a walk together, or where there is an offer and an acceptance of hospitality. Nobody would suggest in ordinary circumstances that those agreements result in what we know as a contract, and one of the most usual forms of agreement which does not constitute a contract appears to me to be the arrangements which are made between husband and wife. It is quite common, and it is the natural and inevitable result of the relationship of husband and wife, that the two spouses should make arrangements between themselves—agreements such as are in dispute in this action—agreements for allowances, by which the husband agrees that he will pay to his wife a certain sum of money, per week, or per month, or per year, to cover either her own expenses or the necessary expenses of the household arid of the children of the marriage, and in which the wife promises either expressly or impliedly to apply the allowance for the purpose for which it is given. To my mind those agreements, or many of them, do not result in contracts at all, and they do not result in contracts even though there may be what as between other parties would constitute consideration for the agreement. The consideration, as we know, may consist either in some right, interest, profit or benefit accruing to one party, or some forbearance, detriment, loss or responsibility given, suffered or undertaken by the other. That is a well-known definition, and it constantly happens, I think, that such arrangements made between husband and wife are arrangements in which there are mutual promises, or in which there is consideration in form within the definition that I have mentioned. Nevertheless they are not contracts, and they are not contracts because the parties did not intend that they should be attended by legal consequences. To my mind it would be of the worst possible example to hold that agreements such as this resulted in legal obligations which could be enforced in the Courts. It would mean this, that when the husband makes his wife a promise to give her an allowance of 30s. or 2 a week whatever he can afford to give her, for the maintenance of the household and children, and she promises so to apply it, not only could she sue him for his failure in any week to supply the allowance, but he could sue her for non-performance of the obligation, express or implied, which she had undertaken upon her part. All I can say is that the small Courts of this country would have to be multiplied one hundredfold if these arrangements were held to result in legal obligations. They are not sued noon, not because the parties are reluctant to enforce their legal rights when the agreement is broken, but because the parties, in the inception of the arrangement, never intended that they should be sued upon. Agreements such as these are outside the realm of contracts altogether. The common law does not regulate the form of agreements between spouses. Their promises are not sealed with seals and sealing wax. The consider原由网ation that really obtains for them is that natural love and affection which counts for so little in these cold Courts. The terms may be repudiated, varied or renewed as performance proceeds or as disagreements develop; and the principles of the common law as to exoneration and discharge and accord and satisfaction are such as find no place in the domestic code. The parties themselves are advocates, judges, Courts, sheriff's officer and reporter. In respect of these promises each house is a domain into which the King's writ does not seek to run, and to which his officers do not seek to be admitted. The only question in this case is whether or not this promise was of such a class or not. For the reasons given by my brethren it appears to me to be plainly established that the promise here was [580] not intended by either party to be attended by legal consequences. I think the onus was upon the plaintiff, and the plaintiff has not established any contract. The parties were living together, the wife intending to return. The suggestion is that the husband bound himself to pay 30 a month under all circumstances, and she bound herself to be satisfied with that sum under all circumstances, and, although she was in ill-health and alone in this country, that out of that sum she undertook to defray the whole of the medical expenses that might fall upon her, whatever might be the development of her illness, and in whatever expenses it might involve her. To my mind neither party contemplated such a result. I think that the parol evidence upon which the case turns does not establish a contract. I think that the letters do not evidence such a contract, or amplify the oral evidence which was given by the wife, which is not in dispute. For these reasons I think the judgment of the Court below was wrong and that this appeal should be allowed.
Appeal allowed.
Solicitors for appellant: Lewis & Lewis.
Solicitors for respondent: Sawyer & Withall, for John C. Buckwell, Brighton.
G. A. S.
[1]余金刚.自由——贯穿卢梭政治哲学的“一大原则”[J].湖北民族学院学报(哲学社会科学版),2012,30(05):110-115.
[2]离婚暂准令（Decree Nisi）是英美国家离婚诉讼中的一种有条件的离婚判令, 也叫中期判决。在离婚诉讼中, 法院一旦发出此种暂准令, 在暂准令发出的六个月又一星期内, 离婚当事人双方不得另行结婚, 但可以反悔。如期间当事人没有异议, 在暂准令发出六个月又一个星期后, 法院将发出离婚绝对判令, 离婚判令绝对生效。
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