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Decoding Judgements: Pondering Postal Paradox in Household Fire & Carriage v Grant

29 September 2023 | CaseSnappy Team

A red Royal Mail post-box on a London street during daytime.


Welcome back to the Decoding Judgements series from CaseSnappy, where we delve into intriguing UK legal cases. Today, we're pivoting to contract law, centred around the key concepts of offer, acceptance, and the mysterious postal rule. Let's delve into Household Fire and Carriage Accident Insurance Co Ltd v Grant [1879] to explore these concepts further.

Shares, Snail Mail, and Slip-ups: Facts of the Case

The protagonists in this case are Household Fire and Carriage Accident Insurance Co Ltd (the plaintiff) and Grant (the defendant). The insurance company issued shares which Grant applied for. The company accepted his application and dispatched a letter of acceptance through post. However, the letter never made it to Grant.

Legal Dispatch: The Issues

The case presented an interesting question: Was a contract formed between Household Fire and Grant? The insurance company contended that acceptance, and therefore contract formation, was confirmed when they posted the acceptance letter. Grant disagreed, arguing that without the receipt of the letter, no contract was formed.

Post Postulated: The Decision

The court ruled that the contract was indeed formed when the letter of acceptance was posted. According to the contractual 'postal rule', established in Adams & Ors v Lindsell & Ors [1818] EWHC KB J59, (1818) 1 B & Ald 681, acceptance is effective from the moment it is posted, regardless of any loss or delay. Thus, Grant was liable to pay for the shares he'd applied for.

A key passage from the judgement by Lord Justice Thesiger portrays this: '… it seems to me … more consistent with the acts and declarations of the parties in this case to consider the contract complete and absolutely binding on the transmission of the notice of allotment through the post, as the medium of communication that the parties themselves contemplated...'

CaseSnappy: Decoding The Legal Labyrinth

Household Fire v Grant unravels an intriguing aspect of contract law through its exploration of the postal rule. Through CaseSnappy's 'Decoding Judgements' series, we continue our endeavour to simplify complex legal judgements for students, professionals and legal enthusiasts.

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