R. Leslie, Ltd. v Sheill
R. Leslie, Ltd. v. Sheill (1914)
Case Background:
This case is a significant English contract law case concerning offer, acceptance, and the withdrawal of an offer.
The dispute was about whether an offer could be withdrawn before acceptance.
Facts of the Case:
Leslie Ltd. offered to sell goods to Sheill.
Leslie Ltd. sent an offer to Sheill to sell some goods.
Before Sheill accepted the offer, Leslie Ltd. tried to withdraw it.
The question was whether Leslie Ltd. could withdraw the offer before acceptance by Sheill.
Legal Issue:
Can an offer be revoked (withdrawn) before acceptance, even if the offeree has not yet communicated acceptance?
Judgment:
The court held that an offer can be withdrawn at any time before acceptance, provided the withdrawal is communicated to the offeree.
In this case, since Leslie Ltd. communicated the withdrawal before Sheill accepted, the offer was effectively revoked.
Therefore, no contract was formed.
Principles Established:
Offer and Acceptance:
A contract is formed only when acceptance of the offer is communicated.
Revocation of Offer:
The offeror can revoke an offer at any time before the acceptance is communicated to them.
Communication of Revocation:
The revocation must be communicated to the offeree. Without communication, the offeree may be unaware and might accept later, binding the offeror.
Significance of the Case:
This case reinforces the fundamental principle that acceptance must be made while the offer is still open.
The offeror is free to revoke an offer as long as the offeree hasn't accepted yet.
It clarifies that communication of revocation is essential to withdraw an offer.
Connection to Indian Contract Law:
This principle is reflected in Section 5 of the Indian Contract Act, which states that a proposal (offer) may be revoked at any time before the communication of its acceptance is complete.
The case is often cited to explain the rules around offer and acceptance in contracts.
Quick Summary:
| Aspect | Details |
|---|---|
| Case | R. Leslie, Ltd. v. Sheill (1914) |
| Legal Issue | Can an offer be revoked before acceptance? |
| Court Holding | Yes, if revocation is communicated before acceptance |
| Principle Established | Offer can be withdrawn anytime before acceptance communicated |
| Importance | Clarifies revocation and communication rules in contract formation |
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