Adams v Lindsell [1818] 1 B & Ald. 681

KEY POINTS

• Mere delivery of an acceptance letter to the postal office, when such a communication is properly addressed to the party involved, constitutes acceptance.

• The defendants are considered to be continuously making the same offer to the plaintiffs while their letter is in transit, and the contract is finalised upon the plaintiffs' acceptance.

• As for the delay in notifying the acceptance, this is due to the defendants' mistake, and therefore, it must be assumed against them that the plaintiffs' response was received in due course through the post.

• This case is pivotal in contract law as it introduced the concept of the "postal rule," which governs the timing of acceptance in contract formation through postal communication. 

FACTS

• The defendants, wool dealers in St. Ives, Huntingdon, sent a letter on September 2, 1817, to the plaintiffs, woollen manufacturers in Bromsgrove, Worcestershire, offering them 800 tods of whether fleeces at 35s. 6d. per tod.

• However, the letter was mistakenly sent to Bromsgrove, Leicestershire, and reached the plaintiffs in Worcestershire on the evening of September 5th. That same evening, the plaintiffs responded, accepting the offer. Due to the post route passing through London, the defendants received the plaintiffs' acceptance only on September 9th.

• Meanwhile, on September 8th, expecting a response on September 7th as per the regular post schedule, the defendants sold the mentioned wool to someone else, given they hadn't received a reply.

JUDGEMENT

• The court ruled in favour of the plaintiffs; a contract was already existing at the time the letter was received by the post office.

COMMENTARY

• The case's principle has endured through legal history, shaping the way contracts are formed and highlighting the significance of postal communication in contract acceptance.

• It's a foundational case that continues to be cited and referenced in contract law discussions and serves as a crucial precedent for understanding the timing of acceptance in contract formation through postal communication.