Dickinson v Dodds 2 Ch D 463 is an English contract law

English contract law

English contract law is a body of law regulating contracts in England and Wales. With its roots in the lex mercatoria and the activism of the judiciary during the industrial revolution, it shares a heritage with countries across the Commonwealth , and the United States...

 case

Case law

In law, case law is the set of reported judicial decisions of selected appellate courts and other courts of first instance which make new interpretations of the law and, therefore, can be cited as precedents in a process known as stare decisis...

, heard by the Court of Appeal, Chancery Division, that held that notification by a third party of an offer's withdrawal is effective just like a withdrawal by the person who made an offer.

Facts

On Wednesday 10 June 1874 Mr Dodds delivered Mr Dickinson an offer to sell some houses for £800, an offer open until 9am on Friday 12 June. On Thursday afternoon, another man called Mr Berry told Mr Dickinson that the houses had already been sold to someone called Mr Allan (who was the second defendant). Mr Dickinson found Mr Dodds in the railway carriage at 7am on Friday morning, leaving Darlington Railway Station, and gave his acceptance there. But Mr Dodds said it was too late. Mr Dickinson sued for breach of contract.

Judgment

James LJ held that Mr Berry had conveyed notice of the withdrawal of the offer. After referring to the document of the 10th of June, 1874 he said the following.
Mellish LJ agreed and said,
Baggallay JA concurred.

Significance

Communication of the withdrawal of the offer can be made by any reliable third party.