A term may be implied to give to a contract what has become known as 'business efficacy'. It is important to note that no term will be implied to give the contract efficacy, unless the implication must arise inevitably. Therefore, a term will not be implied merely on the grounds that such an implication will transform the agreement into a businesslike arrangement, but that, without the implied term, the arrangement would be so unbusinesslike that sensible people could not be supposed to have entered into it. The concept was outlined by Bowen LJ in The Moorcock (1889) 14 PD 64.