Adams v. Lindsell

Nature of the Case

This was an action for the nondelivery of wool according to an agreement.

Facts

The defendant wrote a letter to the plaintiff on September 2, 1817 offering to sell wool under certain conditions. The letter was misdirected by the defendant to Broomsgrove and did not reach the plaintiff until the evening of September 5th. Plaintiff wrote an answer that evening agreeing to the terms but it was not received until September 9th. However, defendant had already sold the wool to another on September 8th. The trial judge ruled for the plaintiff and defendant appealed.

Issue

When is an offer delivered by mail completed and accepted?

Holding and Rule of Law

An offer by post is completed and accepted when the accepting party assents to the terms and puts the letter into the postal system.

If this were not the rule no contract could ever be completed by the post. If an offeror is not bound by his offer when accepted by the offeree till the answer is received, then the offeree ought not to be bound till after he had received notification that the offeror had received their answer and assented to it. And so it might go on ad infinitum. Defendants must be considered in law as making during every instant of the time their letter was traveling, the same identical offer to plaintiff and then the contract is completed by the acceptance of it by the latter. The delay of notification to the defendant was due to his own mistake.

Disposition

Affirmed.