The police authority has a legitimate claim for the 'special police services' provided. Although the police have a duty to maintain law and order, the provision of services above and beyond their statutory duty, such as extensive policing inside and outside the stadium, constitutes special services for which the club can be charged. In Glasbrook Bros v Glamorgan CC [1925] AC 270, it was established that the police can charge for services that go beyond their public duty. Similarly, Harris v Sheffield United FC [1987] 2 All ER 838 affirmed that clubs can be liable for additional police services requested for their benefit, representing a good consideration in exchange for the special services provided.

Key Point: Consideration in contract law must involve an exchange of value. When a party requests services that exceed statutory obligations, this constitutes additional consideration, legitimising claims for payment. This principle ensures fair compensation for services rendered beyond basic duties.