Gibbons v Proctor [1891]

Court: High Court, Queen’s Bench

Facts: A reward of £25 was offered for information leading to the arrest of a criminal. The advertisement stated that the information must be given to the Superintendent. A police officer, unaware of the offer at the time, asked a colleague to forward useful information to the Superintendent. Before the information reached the Superintendent, the police officer became aware of the reward offer.

Issue: Can an individual claim a reward for information provided before becoming aware of the offer?

Held: The court held that the police officer was entitled to claim the reward. Advertisements offering rewards for information are considered offers. Since the officer became aware of the offer before the information reached the Superintendent, the acceptance of the offer was valid.

💡Leveluplaw: Gibbons v Proctor establishes that reward advertisements are treated as offers. However, this case is sometimes misinterpreted to suggest that acceptance in ignorance of an offer is valid. In reality, the court held that the officer had knowledge of the offer before completing the act of acceptance. Therefore, the case does not strongly support the idea that one can accept an offer in ignorance, especially if the accepting party becomes aware of the offer before completing the required action.

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Felthouse v Bindley [1862] EWHC CP J35

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Brinkibon Ltd v Stahag Stahl GmbH [1983] 2 AC 34