Oral contracts may fail in several circumstances, as provided for by the various fraud laws in each state or under the UCC, which require that certain oral contracts or conditions contained in them be considered valid in writing. Globe Motors, Inc. Ors v TRW Lucas Varity Electric Steering Ltd. – Anor,  EWCA Civ. 396 is the last statement of the Court of Appeal of England and Wales on whether the parties can make an oral amendment to the contract, regardless of a clause imposing a written amendment (an “anti-oral” amendment clause).
 Many contracts contain clauses that require changes to a written agreement to be written, but they are not always enforceable. “No Oral Modification” clauses – or nomadic clauses – are often used in commercial contracts as construction conditions to limit future changes or involuntary changes to the contract. Globe and TRW entered into a long-term supply contract, whereby TRW was to acquire certain engines only from Globe, and Globe was to supply these engines only for tRW. TRW`s requirements changed and engines had to be purchased slightly different from those listed in the supply agreement with The Globe. A dispute ahead adle erupted over whether the new engines were included in the supply agreement and, therefore, whether TRW was obliged to purchase these engines only from Globe or whether it could be delivered to a Globe competitor (as TRW did). The Court of Appeal sided with TRW and found that the new engines were significantly different from those under the delivery agreement. It therefore concluded that TRW had not breached the treaty. The second question was whether Globe Motors Portugal (“Porto”), a subsidiary of The Globe, was a contracting party to the agreement. Porto was not a contracting party to the written contract, but the judge found that the agreement was varied or nullified by the behaviour of the parties, since they operated in their operations for a long time under the agreement, as if Porto had no party. The delivery agreement contained an article which provided that it could only be amended by a written document signed by both parties. A type of contract that is written orally or amended orally without being recorded in writing. Such contracts are sometimes called Parol contracts.