1 Identifying Terms In identifying the express terms, the starting point is to identify the written document between Margret and Michael itself. Clause 1 is an entire agreement clause, which is regard as conclusive evidence and excludes any pre-contractual statements as contractual terms1. However, words used in Clause 1 could not prove the contractual terms are only to be shown in the document.2 A flexible approach would be applied in determining whether the document is wholly in written.3 Under this avenue, unless the contract is ascertained wholly in writing, the parol evidence rule [‘PER’] could