Hyde v Wrench [1840]
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Hyde v Wrench [1840] EWHC Ch J90 is a notable English contract law case that deals with the concept of counter-offers and their impact on the original offer. The case involved a dispute over the sale of a farm between Mr Wrench (the defendant) and Mr Hyde (the plaintiff).
Wrench initially offered to sell his farm to Hyde for £1200. Hyde rejected the offer. Later, on June 6, 1840, Wrench wrote to Hyde's agent, offering to sell the farm for £1000, explicitly stating that it was the final offer and would not be altered. Hyde responded by offering to buy the farm for £950 by June 8. Wrench, upon examining Hyde's counter-offer, refused to accept it and informed Hyde of this on June 27. On June 29, Hyde agreed to buy the farm for the original price of £1000 without seeking any further agreement from Wrench.
Lord Langdale, delivering the judgment, held that there was no valid and binding contract between the parties for the purchase of the property. Lord Langdale's reasoning is based on the principle that making a counter-offer amounts to a rejection of the original offer. Specifically, Lord Langdale stated that when Wrench made the initial offer to sell the farm for £1000, a binding contract could have been formed if Hyde had unconditionally accepted it. However, instead of accepting Wrench's offer, Hyde made a counter-offer of £950, effectively rejecting Wrench's original proposal. Lord Langdale concluded that by making a counter-offer, Hyde had rejected Wrench's offer, and it was not within his competence to later revive the original proposal by attempting to accept it. As a result, it was held that there was no obligation or contract between the parties.
This case is significant in contract law for establishing the principle that a counter-offer operates as a rejection of the original offer, preventing the original offer from being later accepted and forming a binding contract.
Wrench initially offered to sell his farm to Hyde for £1200. Hyde rejected the offer. Later, on June 6, 1840, Wrench wrote to Hyde's agent, offering to sell the farm for £1000, explicitly stating that it was the final offer and would not be altered. Hyde responded by offering to buy the farm for £950 by June 8. Wrench, upon examining Hyde's counter-offer, refused to accept it and informed Hyde of this on June 27. On June 29, Hyde agreed to buy the farm for the original price of £1000 without seeking any further agreement from Wrench.
Lord Langdale, delivering the judgment, held that there was no valid and binding contract between the parties for the purchase of the property. Lord Langdale's reasoning is based on the principle that making a counter-offer amounts to a rejection of the original offer. Specifically, Lord Langdale stated that when Wrench made the initial offer to sell the farm for £1000, a binding contract could have been formed if Hyde had unconditionally accepted it. However, instead of accepting Wrench's offer, Hyde made a counter-offer of £950, effectively rejecting Wrench's original proposal. Lord Langdale concluded that by making a counter-offer, Hyde had rejected Wrench's offer, and it was not within his competence to later revive the original proposal by attempting to accept it. As a result, it was held that there was no obligation or contract between the parties.
This case is significant in contract law for establishing the principle that a counter-offer operates as a rejection of the original offer, preventing the original offer from being later accepted and forming a binding contract.
