Facts of Lalman Shukla v. Gauri Dutt (1913)

This case deals with communication and acceptance of an offer in contract law.

  • Gauri Dutt, a businessman, sent his servant, Lalman Shukla, to search for his missing nephew.
  • After Lalman had already left to search, Gauri Dutt announced a reward for anyone who found and brought back the missing boy.
  • Lalman eventually found and returned the boy but was unaware of the reward at the time of his efforts.
  • Later, when Lalman learned about the reward, he claimed the money, but Gauri Dutt refused to pay.
  • Lalman then filed a lawsuit demanding the reward.

Final Order (Judgment)

The Allahabad High Court ruled in favor of Gauri Dutt, holding that:

  1. There was no valid contract, as Lalman was unaware of the reward when he performed the act (finding the boy).
  2. Acceptance of an offer requires knowledge of the offer—Lalman had already acted before knowing about the reward, so there was no acceptance.
  3. Lalman was performing his duties as a servant under his employment and was already obligated to search for the boy. His actions did not constitute acceptance of a contractual offer.

Conclusion

Since Lalman had no knowledge of the offer at the time of performing the act, he was not entitled to the reward. This case established the principle that an offer must be communicated and accepted to create a valid contract.

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