Furthermore, as Lord Reid stated in White and Carter (Councils) Ltd v McGregor, the need for co-operation of the other contracting party will usually act as a further limitation on the scope of the decision. In other words, if the innocent party requires the co-operation of the other contracting party in order to fulfil their obligations under the contract, this will prevent the innocent party claiming the contract price. Indeed, it has been confirmed by Megarry J, that co-operation in this context means passive as well as active co-operation: Hounslow London Borough Council v Twickenham Garden Developments Ltd [1970] 3 WLR 538.