The recent judgement in Hodder v Peacekeepers Foundation [2026] EWCC 37 serves as an interesting and engaging read on the topic of unilateral offers, in the context of a competition advanced by the Defendant for a prize to anyone who could disprove their beliefs. The judgement concerns the Claimant’s application for strike out, or in the alternative summary judgement, in respect of the Defence to the claim. The matter was heard by Deputy District Judge Blitz who, among other accolades, is a former LPC Law advocate.

 

The Claim

The Defendant, via its website, promoted the “No Obligation Challenge”. This competition challenged anyone to disprove the Defendant’s belief that unless an individual expressly consents to a statute being binding on them, it has no legal effect. This may ring a bell, as this view is one of those often advanced by Freeman of the Land, whom LPC Law advocates occasionally deal with at hearings.

The Claimant submitted a document to the Defendant in December 2025, responding to the challenge and attempting to win the prize fund of £23,665. The Claimant’s position was that the “No Obligation Challenge”, per the terms on the Defendant’s website, amounted to a unilateral offer that he had performed, and he therefore claimed the amount of the prize fund plus interest.

The Defendant’s Defence to the claim was two-fold. Firstly, the Claimant’s document did not comply with the terms of the unilateral offer, and so it followed that there was no successful acceptance of any unilateral offer that had been made. Secondly, that the website’s terms and conditions made clear that "the website provided no goods or services, contained no offers or invitations to treat, and was not intended to create legal relationships". Therefore, there was no such offer and no contract created.

 

The Unsurprising Stike Out

As to the Defendant’s second position in their defence, DDJ Blitz had no hesitation in striking this out and pointing out that their argument was clearly circular. In order for the Defendant to be able to rely on this argument of contractual estoppel, there would have to be a contract. Yet these terms, if enforceable, would mean that there could be no contract. The argument clearly disclosed no reasonable grounds for defending the claim, and DDJ Blitz therefore used his discretion to strike out this part of the Defence under CPR 3.4(2)(a).

 

Summary Judgement

DDJ Blitz assessed two points when determining summary judgement. Firstly, the effect of the terms and conditions on the Defendant’s website and whether the wider circumstances indicated that the parties did not intend to create legal relations. Secondly, whether the Claimant complied with the terms of the “No Obligation Challenge”.

When assessing the first point, DDJ Blitz had regard to the evidence available which included screenshots of the website and communication between the Claimant and the Defendant. This evidence proved damning for the Defendant with the most ironic coming in the form of the words on the website encouraging donations: "The more you pledge, the greater the embarrassment of their failing to prove that an obligation can exist without agreement". This, coupled with the wording of the advertisement for the challenge: "SHOW USE THE EVIDENCE", "WIN THE PRIZE", and "TAKE THE CASH!", led DDJ Blitz to draw analogy to everyone’s favourite unilateral offer case: Carlill v Carbolic Smoke Ball Company. It was found that the advertisement, backed by the prize fund and donation encouragement, created the intention to distribute the fund should the evidence be shown. Therefore, the terms and conditions did amount to a unilateral offer and an intention to create legal relations by contract.

The issue for DDJ Blitz on the second point was considering the terms of the “No Obligation Challenge” as a matter of contractual construction. The challenge criteria were set out as the challenge "To provide written publicly available expressed legislative evidence that parliament can lawfully (as legislatively defined in the Act of Settlement 1700 as an individuals [sic] birthright) create an obligation that binds any individual or group of individuals".

The Defendant attempted to argue that the criteria of the challenge was to include wording at the top of the challenge page of the website. This stated that the prize fund would be awarded if someone showed “a simple piece of paper produced by parliament where it says parliament can do whatever it wants!!! Show us parliament can impose its will on any individual without a binding obligation entered into by freewill [sic]”.

 

This position from the Defendant was clutching at straws. The Claimant, as their performance, had submitted a three-page document referring to various statutes and case law as evidence to the contrary of the Defendant’s beliefs.  To the Defendant, the Claimant had not abided by the terms as the task required the production of a single, express legislative document meeting specific criteria, rather than the Claimant’s submission of argument, interpretation and commentary. The Claimant had therefore not exactly performed the stated condition.

The Judge dismissed this argument and found that the Claimant’s submission of their document was proper performance of the challenge’s criteria, with the criteria of the challenge more being one of substance and not form. The Claimant had produced a document with evidence that they saw as rebutting the Defendant’s beliefs. DDJ Blitz found that the Defendant’s case on this point was “largely, if not wholly, hopeless.”

Ultimately, the Judge found that the Defendant had no real prospect of success at trial and there was no other compelling reason for the matter to be disposed of at trial, especially given that there was no prospect of further evidence becoming available that the Defendant could not have put before the Court for this hearing. CPR 24.3 had been made out, and judgement was made in favour of the Claimant for the sum of £23,665 plus interest.

Whilst obiter, DDJ Blitz does go on to comment that had he been required to consider the Claimant’s interpretation of the challenge and the merits of the content of the Claimant’s submission, he would have granted summary judgement on this basis also. This is in part due to the Defendant’s beliefs being described as pseudo-legal nonsense.

 

Conclusion

DDJ Blitz thoroughly and satisfyingly dismantled the Defendant’s position in this judgement, and I would urge readers of this article to read it in full. Both legally stimulating and entertaining, the judgement reminds people of what they learned in their first year of law school regarding contracts and unilateral offers, whilst providing backing for those who may think about taking on competitions like the “No Obligation Challenge”.