Also known as: Stevenson Jaques & Co v McLean
Court: Queen’s Bench Division
Judgment Date: 25 May 1880
Where Reported: (1880) 5 Q.B.D. 346; [1880] 5 WLUK 57
Legal Issues in Stevenson v McLean
Stevenson v McLean addressed issues around contract formation, particularly acceptance and revocation.
The case delves into whether an inquiry about an offer’s terms negates the original offer, and how the timing of acceptance impacts the validity of a contract.
It scrutinises the legal consequences of withdrawing an offer and whether a request for further information about an offer can be interpreted as a counter-offer, thus rejecting the initial proposal.
This dispute highlights how offers are communicated and accepted, and the conditions under which they can be legally revoked.
Material Facts in Stevenson v McLean
The dispute arose from a series of communications between Stevenson, Jaques & Co. (the plaintiffs) and McLean (the defendant) regarding the sale of iron.
McLean offered to sell iron at a specified price, holding the offer open until Monday. The plaintiffs queried the offer’s terms on Monday, seeking to negotiate the delivery period.
Before receiving a response, the plaintiffs accepted McLean’s original offer, unaware that McLean had already sold the iron to another party.
Judgment in Stevenson v McLean
The court held in favour of the plaintiffs, ruling that their query did not constitute a rejection of the original offer but was merely an inquiry for clarification.
Therefore, when the plaintiffs accepted the offer, a contract had been formed, obligating McLean to fulfil it.
The court’s decision emphasised the importance of communication in the offer and acceptance process within contract law – see Shuey v United States (1875).
The Reason for the Decision in Stevenson v McLean
The court’s decision in Stevenson v McLean was predicated on the nuanced interpretation of contract law principles, particularly focusing on the nature of inquiries made during the offer and acceptance process – see Household Fire Insurance v Grant (1879).
The court differentiated between an inquiry seeking further details or clarification on the terms of an offer and an outright rejection or counter-offer.
It underscored that such inquiries do not terminate the original offer, allowing for the possibility of acceptance unless the offer is expressly revoked by the offeror in a manner that is communicated to the offeree.
The court further emphasised that the effectiveness of revocation hinges on its receipt by the offeree, thus, actions taken by the offeror unbeknownst to the offeree, such as selling the goods to another party, do not in themselves invalidate the offer.
This interpretation underscores the legal principle that clear and unequivocal communication is essential in the formation of contracts, ensuring that offers and revocations are distinctly conveyed to maintain the integrity of contractual agreements.
Read case: Dunlop Pneumatic Tyre Co Ltd v Selfridge (1915)
Legal Principles in Stevenson v McLean
Stevenson v McLean solidifies key contract law principles: acceptance must mirror the offer exactly for contract formation, and inquiries about offer terms are not rejections or counter-offers but requests for information.
Crucially, it establishes that offer revocation must be communicated to the offeree to take effect, emphasising the vital role of clear, timely communication in establishing contractual agreements – see Tinn v Hoffman (1873).
This principle supports the framework for contractual negotiations, ensuring parties are aware that offers stand until explicitly withdrawn and received by the other party
