What Routledge v Grant (1828) Teaches About Revocable Offers?

Routledge v Grant

Routledge v Grant (1828) is a foundational contract law case on whether an offeror can revoke an offer despite promising to keep it open for a fixed period. Given below is a brief summary.

  • Citations: Routledge v Grant (1828) 4 Bing 653; 130 ER 920
  • Court / Year: Court of Common Pleas, 1828
  • Year of Decision: 1828
  • Areas of Law: Offer and Acceptance, Revocation of Offers, Consideration (Option Contracts), Formation of Contracts

Key Facts: Routledge v Grant

Grant (defendant) wrote to Routledge (plaintiff) offering to buy the plaintiff’s lease and stated the offer would remain open for six weeks.

Before Routledge accepted, Grant changed his mind and sent a letter withdrawing the offer.

On the other hand, Routledge then attempted to accept within the six-week period (and had taken steps in reliance), but the defendant refused to complete the transaction.

Legal Issue

Was the defendant bound to keep the offer open for the stated six weeks so that the plaintiff’s later acceptance created a binding contract?

Court’s Decision in Routledge v Grant

The court held that the offer was validly revoked before acceptance. No binding contract arose.

Further, the mere promise to keep the offer open for six weeks was not binding unless it was supported by consideration (or some other enforceable option mechanism).

Therefore, Routledge’s attempted acceptance after the revocation did not create a contract.

Ratio Decidendi / Legal Principles

An offeror may revoke an offer at any time before it is accepted, even if the offer stated it would remain open for a period, unless the offeree has given consideration to make the promise to keep it open (i.e. an enforceable option).

In simple terms,

Offers can be cancelled any time before acceptance.

Saying “offer open for 6 weeks” is not binding unless the other person pays or gives something in return.

No consideration = no obligation to keep the offer open.

Practical Significance

Routledge v Grant is an early authority for the principle that offers are revocable up until acceptance, and that a stated time period in the offer does not by itself make the offer irrevocable. To make an offer irrevocable for a period (an “option”), the offeree must give consideration (or some other legally-recognized basis must exist). This case is commonly cited in contract-formation doctrine.

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