Adams v. Lindsell
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| Adams v. Lindsell | |
| Court | High Court of Justice, King's Bench Division |
|---|---|
| Citation | 106 Eng.Rep. 250 |
| Date decided | 1818 |
Facts
Before 1800, parties signed a contract face-to-face. By the early 1800s, making & accepting offers by mail was becoming commonplace.
On September 2nd 1817, Mr. Lindsell mailed a letter to Mr. Adams who was a wool manufacturer.
Defendant (Lindsell) sent, by mail, an offer to sell wool. Due to Defendant's negligence, the offer was received late on September 5th 1817.
Plaintiff (Adams) immediately accepted on September 5th 1817 & replied via mail.
Lindsell received the Adams mailed reply on September 9th. Defendant (Lindsell) had already sold wool on September 8th.Issues
Was Plaintiff's (Adams) purported acceptance actually an acceptance?
Holding
Yes, Plaintiff had accepted.
Reasons
There was a "meeting of the minds" as soon as Plaintiff posted his acceptance in the mail.
Rule
The mailbox rule states that acceptance takes effect as soon as a letter stating such is posted.
Resources
| Date | Action |
|---|---|
| September 2nd 1817 | Lindsell (seller of wool) mailed a offer letter to Adams (wool manufacturer & buyer). |
| September 5th 1817 | Adams received the letter |
| September 5th 1817 | Plaintiff (buyer Adams) immediately accepted to buy a large quantity of sheep wool on September 5th 1817 |
| September 5th 1817 | Adams replied via mail |
| September 7th 1817 | Lindsell (seller) hasn't heard from Adams (buyer) |
| September 8th 1817 | Lindsell sold the wool to another buyer (not Adams) |
| September 9th 1817 | Lindsell (seller) received the acceptance letter |
