Court: Court of Appeal
Judgment Date: 1 April 1876
Where Reported: (1876) 2 Ch. D. 463; [1876] 4 WLUK 1
Legal Issues in Dickinson v Dodds
The case of Dickinson v Dodds revolves around the legal issue of offer and acceptance in contract law, specifically the revocation of an offer.
Dickinson v Dodds addresses whether an offer can be revoked before it is accepted, and if so, what constitutes an effective revocation.
The case also examines the impact of a third party’s knowledge of the offer’s revocation on the original offeree’s rights.
Material Facts in Dickinson v Dodds
In June 1874, Dodds offered to sell a property to Dickinson for £800, stating that the offer would remain open until 9 A.M. on Friday, 12th June.
Before Dickinson accepted the offer, Dodds sold the property to Allan on the 11th of June. Dickinson, upon learning of the sale to Allan, attempted to accept Dodds’ original offer before the 9 A.M. deadline on the 12th of June.
The acceptance was communicated to Dodds, but he refused it, stating that he had already sold the property.
Dickinson filed for specific performance, asserting that a binding contract had been formed.
Judgment in Dickinson v Dodds
The court held that there was no binding contract between Dodds and Dickinson.
It found that Dodds’ offer was effectively revoked when he sold the property to Allan before Dickinson accepted the offer.
The court further reasoned that Dickinson, having knowledge of the sale to Allan, could not accept the original offer, as there was no longer an offer to accept.
The Reason for the Decision in Dickinson v Dodds
The decision was primarily based on the principles of offer and acceptance in contract law.
The court emphasised that an offer is a statement of terms on which the offeror is willing to be bound, but it must be accepted in its exact terms without any modifications to form a contract.
Here, the offer was not accepted before it was revoked. The court clarified that the act of selling the property to Allan constituted a revocation of the offer made to Dickinson, as it was inconsistent with the continuance of the offer.
The court also highlighted the importance of communication in the revocation of offers.
It held that the revocation of an offer is effective when the offeree has actual knowledge of the revocation, as in this case, where Dickinson was aware of the sale to Allan before attempting to accept Dodds’ offer.
The court rejected the notion that a formal notification of revocation was necessary, considering the knowledge of the sale to Allan sufficient.
Legal Principles in Dickinson v Dodds
Dickinson v Dodds establishes legal principles in the law of contract, particularly concerning the revocation of offers.
Dickinson v Dodds demonstrates that an offer can be revoked at any time before acceptance, and the revocation is effective when the offeree has actual knowledge of it.
The decision underscores that a contract is formed only when there is a “meeting of minds,” and this cannot occur when one party has effectively withdrawn their offer.
The case also highlights that actions inconsistent with the continuation of the offer, such as selling the subject matter to a third party, can serve as an effective revocation of the offer.
