Gaming Act 1845
The Gaming Act 1845 was an Act of the Parliament of the United Kingdom. The Act's principal provision was to deem a wager unenforceable as a legal contract. The Act received Royal Assent on 8 August 1845. Sections 17 and 18, though amended, remained in force until 1 September 2007.
Background
Increasing concern as to the damaging social effects of gambling gave rise to a select committee of the House of Commons whose recommendations were implemented by the Act. The policy of the Act was to discourage betting.However, following a 2001 report by Sir Alan Budd, in 2002, the UK government accepted that wagers should cease to be unenforceable as contracts, seeking to introduce a new liberalised regulatory regime in order to encourage the gambling industry.
Repeals
Sections 1 to 9 and 15 and 16 and 19 to 24 and 26, and the First and Second Schedules, were repealed by Part I of Schedule 6 to the Betting and Gaming Act 1960.Sections 10 to 14 and the Third Schedule were repealed by section 1 of, and the Schedule to, the Billiards Act 1987
Section 25 was repealed by Part XIX of Schedule 1 to the Statute Law Act 1976
This Act was repealed for Northern Ireland by of, and Schedule 21 to, the Betting, Gaming, Lotteries and Amusements Order 1985.
The whole Act was repealed in the Republic of Ireland by the Gaming and Lotteries Act 1956.
Exclusion
This Act was excluded by of the Gaming Act 1968.Section 1 – Repeal of part of the Unlawful Games Act 1541
Section 1 repealed the Unlawful Games Act 1541, as to so much- whereby any game of mere skill, such as bowling, coyting, cloyshcayls, half bowl, tennis or the like, was declared an unlawful game,
- which enacted any penalty for playing at any such game of skill as aforesaid,
- which enacts any penalty for lacking bows or arrows, or for not making and continuing butts,
- which regulates the making, selling, or using of bows and arrows,
- requires the mayors, sheriffs, bailiffs, constables, and other head officers within every city, borough, and town within the Realm, to make search weekly, or at the farthest once a month, in all places where houses, alleys, plays, or places of dicing, carding, or gaming shall be suspected to be had, kept, and maintained,
- as makes it lawful for every master to license his or their servants, and for every nobleman and other having manors, lands, tenements, or other yearly profits for term of life, in his own right or in his wife's right, to the yearly value of an hundred pounds or above, to command, appoint, or license, by his or their discretion, his or their servants or family of his or their house or houses to play at cards, dice, or tables, or any unlawful game.
Section 15 – Repeal of other laws
Section 15 repeals the following:- Gaming Act 1664 16 Cha. 7
- Gaming Act 1710 9 Ann, c. 19 as was not amended by Gaming Act 1835 5 & 6 Wil. 4 c. 41
- Gaming Act 1744 18 Geo, 2 c.34
Section 17 – Cheating at play
The words of enactment at the start were repealed by the Statute Law Revision Act 1891.
The words in square brackets were substituted for the words "be deemed guilty of obtaining such money or valuable thing from such other person by a false pretence, with intent to cheat or defraud such person of the same, and, being convicted thereof, shall be punished accordingly" by sections 33 and 36 of, and Part III of Schedule 2 to, the Theft Act 1968.
Two hundred pounds
Section 32 of the Magistrates' Courts Act 1980 provided that the reference to two hundred pounds was to be construed as a reference to the prescribed sum.
The following cases are relevant:
- R v Darley 1 Stark NP 359, 171 ER
- Cooke v Stratford 13 M & W 379, 2 Dow & L 399, 4 LT 138a
- R v Hudson Bell CC 263
- R v O'Connor and Brown 45 LT 512, 46 JP 214, 15 Cox 3
- R v Moore, 10 Cr App R 54, CCA
- R v Lawler, 14 JP 561
- R v Governor of Brixton Prison, ex parte Sjoland and Metzler 3 KB 568, 29 TLR 10, 77 JP 23
- R v Leon KB 136, 30 Cr App R 120, 61 TLR 100, CCA
- R v Butler, 38 Cr App R 57, CCA
- R v Clucas and O'Rourke 1 WLR 244, 1 All ER 438, 43 Cr App R 98, 123 JP 203, CCA
- R v Harris and Turner 2 QB 442, 2 WLR 851, 2 All ER 294, 47 Cr App R 125, CCA
Section 18 – Gambling contracts deemed void
This section concerned whether unpaid winnings accrued from gambling could be sued for in a court of law. The Act made it clear that they could not because winnings from gambling were to be treated as a "debt of honour" and as such could not be treated as a financial debt. The Act read:This section was extended by the Gaming Act 1892.
However, a bet on the Horserace Totalisator Board, also known as The Tote, did not fall within the scope of the Act.
Further, by the 1980s, it was feared that complex commercial risk management instruments and contracts, such as derivatives could fall foul of the Act. Provision was made that a contract would not be void if at least one of the parties entered into it for legitimate business purposes. The exemption is now found in the Financial Services and Markets Act 2000 s 412. The Gambling Act 2005
removed the "debt of honour" clause that made gambling winnings exempt from legal action if they were not paid. This meant that unpaid winnings could now be pursued in a court of law.
Section 19 – Feigned issues abolished
Court of law or equity that desired to have any question of fact decided by a jury had it presented in the form of feigned issues, by stating that a wager was laid between two parties interested in respectively maintaining the affirmative and the negative of certain propositions. It was enacted that in every case where any court of law or equity desires to have any question of fact decided by a jury it should the directly state the question of fact in dispute, with such persons being plaintiffs and defendants as the court may direct, rather than as a feigned issue of a wager.Ireland and Northern Ireland
The Act was in force in Ireland until partition. It consequently became the law of the Irish Free State on 6 December 1922, and then of its successor states until its repeal in 1956. When the autonomous region of Northern Ireland seceded from the Irish Free State and rejoined the United Kingdom on 7 December 1922, the Act became the law of Northern Ireland until repeal.Cases
- Close v Wilson EWCA Civ 5, a promise to money paid under an agreement to bet cannot be enforced because of the Gaming Act 1892 s 1, but the payer has a claim in restitution for the winnings and for any money used for purposes other than betting.