Interfoto Picture Library Ltd. v. Stiletto Visual Programmes Ltd.

The general rule where D has attempted to incorporate clauses from unsigned documents into his contract with P is that such clauses will be incorporated provided there is “reasonably sufficient notice” of them. This has been well established since Parker v. South Eastern Ry. Co.1 However, under the “red hand” rule, it is possible that, although there is sufficient notice to incorporate most of D’s clauses, one of them will not be incorporated, despite the fact that it is printed just as clearly as the rest, because it is of a type requiring a greater degree of notice. It is appropriate to call this rule the “red hand” rule because of the well known dicta of Denning,