One of the oldest forms of business contracts it is the contracts under seal (Burrows, 2009). These types of contracts are a traditionally enforceable legal document that is stamped with a seal. This act of putting a seal on the agreement acts as the solemn acceptable of the parties of the terms and conditions of the agreement, thus, this type of contract does not need consideration for it to be valid (Burrows, 2009). This type of contract is seldom used in our present times and transactions used to be done under seal are now covered under implied contracts. Implied contracts arise from the mutual agreement are promises of the parties that have not been put expressly in writing (Burrows, 2009). What makes this type of contact binding is the intent of the parties to honor the unwritten obligations. The existence of an implied contract relies on the substance of its existence thus the acts or conducts of the parties that are to be bound by this contract determines its validity and enforceability. Since the parties commit and bind themselves to honor the implied agreement, this type of agreement has the same affects as the express contact (Burrows, 2009). Under the express contract, the parties express stipulates their agreements through either in oral or written forms. For an express contract to be considered valid the offeror must make his or her offer expressly and such offer must be expressly accepted by the offeree (Burrows, 2009). The general rule here is that for a contract to be valid, there must be a valid offer, the offer must be accepted, the contract must involve a legal consideration, the parties must have the capacity to enter into a contract and the contract must comply with the formalities of law (Kendrick, 2008). If these conditions are met, the contact is said to be valid. According to the court in the case of Smith v. Hughes1, the acceptance of the offer must be conveyed tothe offeror for it to be valid.