Implied Term as to Satisfactory Quality – Section 14(2) of the Sale of Goods Act
In our last post, we explored Section 13 of the Sale of Goods Act, which ensures that goods delivered must correspond with their description. That rule protects buyers from paying for one thing but receiving another.
But description alone is not enough. Goods might perfectly match their description and still be completely unsatisfactory. Think of a “new smartphone, model X” that arrives with the correct model number but a battery that lasts only 20 minutes. On paper, it matches the description, but in reality, it is unusable.
This is where Section 14(2) comes into play: the implied term that goods supplied must be of satisfactory quality.
What does “satisfactory quality” mean?
The Act does not leave this phrase vague. Goods are considered satisfactory if a reasonable person would regard them as acceptable, taking into account the description of the goods, the price, and any other relevant factors.
A reasonable person here means not the most demanding buyer, but also not the most careless one. It is the “average consumer” who makes decisions in a normal, everyday way. For example:
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If you pay a premium price for a luxury car, you expect flawless performance, no strange noises, and long-term durability.
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If you buy a second-hand bike for €50, you cannot reasonably expect it to perform like a brand-new one — but you can expect it to be safe and usable.
So, “satisfactory” is not absolute. It depends on context: the type of product, its price, and the promises made about it.
The key aspects of satisfactory quality
Section 14(2A) and (2B) explain that quality includes several elements. Goods should be:
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Free from minor defects – A brand-new phone should not have scratches on its screen.
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Safe – A kettle should not leak electricity or cause burns.
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Durable – A washing machine should last for a reasonable time before breaking down.
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Fit for ordinary use – A winter coat should actually keep you warm in winter conditions.
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Appearance and finish – Goods should look as they are supposed to, without flaws that reduce value.
These aspects together shape the “reasonable person” test.
example
Imagine a customer buying a new VR headset in 2025, advertised as “the latest immersive gaming experience, lightweight and durable.”
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The headset arrives exactly as described: correct model, correct packaging.
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But after two weeks of use, the plastic headband cracks under normal handling, and the lenses fog up within 10 minutes, making it nearly impossible to play.
Does it match the description? Yes.
Is it of satisfactory quality? Clearly not.
A reasonable person would not consider a €700 VR headset “satisfactory” if it breaks under ordinary conditions so quickly. Under Section 14(2), the buyer has the right to reject the goods or claim a remedy.
Why does this matter?
The principle shifts responsibility from caveat emptor (let the buyer beware) to caveat venditor (let the seller beware). Modern consumers cannot be expected to test every product before buying. Sellers, especially in 2025 with global online commerce, must ensure that their goods meet a baseline of satisfactory quality.
In short:
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Section 13 protects buyers against wrong descriptions.
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Section 14(2) protects buyers against poor quality, even when the description is correct.
Together, they form the backbone of consumer protection in sales law.
What does Section 14(2) of the Sale of Goods Act require?
Goods must be of satisfactory quality, judged by what a reasonable person would find acceptable.
Goods only need to match their description, regardless of condition.
What does “satisfactory quality” depend on?
The description, the price, and any other relevant circumstances.
The seller’s personal opinion about the goods.
Which of the following is NOT part of satisfactory quality under Section 14(2A/B)?
Appearance and finish of the goods
Safety, durability, and fitness for ordinary use
The buyer’s mood when purchasing the goods
What remedy does a buyer have if goods are not of satisfactory quality?
The buyer can reject the goods or claim a suitable remedy.
The buyer must keep the goods without any remedy.
Why is Section 14(2) especially important in 2025 for online commerce?
Buyers often cannot inspect goods beforehand, so the law ensures baseline quality and safety.
It allows sellers to reduce standards since buyers shop online.
