Case Brief of Fitch v Snedaker (1868)
Case name & citation: Fitch v Snedaker (1868) 38 N.Y. 248
Year of the case: 1868
Jurisdiction: New York, America
Area of law: Communication of offer; acceptance
Facts of the case (Fitch v Snedaker)
Snedaker, the defendant, declared to offer a reward to anyone who would return his lost dog. Fitch (the plaintiff) found and brought the dog to Snedaker, without any knowledge of the offer of reward.
Later, on knowing about the same, Fitch claimed the reward from the defendant but the defendant refused to pay. The plaintiff, thus, filed a suit to claim the reward.
Issue raised
Can Fitch recover the reward offered by Snedaker?
Judgment in “Fitch v Snedaker”
The decision was taken in favor of Snedaker.
It was held that Fitch was not entitled to claim the reward because he can’t be said to have accepted the offer which he was not aware of.
Governing principles behind the decision
One of the legal rules for a valid offer is that an offer must be communicated to the person to whom it is made. An offer shall be complete only when it is communicated to the offeree. One should note that a person can accept an offer only when he knows about it. An offer that is accepted without its knowledge does not confer any legal rights on the acceptor. In other words, there cannot be any valid acceptance unless there is awareness or knowledge of the offer.
Conclusion
An acceptor must be aware of the offer’s existence and its terms.
A similar case to this
R v Clarke (1927)
R v Clarke (1927) is another contract law case from Australia that talks about the same issue.
In this case, the government of Western Australia had offered a reward for information leading to the arrest and conviction of the individuals who were responsible for the murders of two police officers. A suspect, Evan Clarke provided this information after being arrested for this offense. Even though Clarke had once known about the offer, however, at the time when he provided the information, he had no intention of claiming any reward and had, in fact, forgotten about it.
The Court said that how can there be consent or assent to something that the party has never heard of? Assent cannot occur in the absence of knowledge of the offer; hence, ignorance of the offer is the same whether it results from never hearing about it or from forgetting it after hearing about it.
Held that he could not recover the reward.
List of references:
- https://egyankosh.ac.in/bitstream/123456789/13367/1/Unit-2.pdf
- https://s3.studentvip.com.au/notes/20180-sample.pdf
- https://www.sscasc.in/wp-content/uploads/downloads/BCOM/Business-Law.pdf
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