Williams v Carwardine (1833): A Case Summary

Case name & citation: Williams v Carwardine (1833) 4 Barnewall and Adolphus 621; 2 LJKB 101; 110 ER 590

Year of the case: 1833

Jurisdiction: Court of King’s Bench

Area of law: Communication of offer; acceptance

What is the case about?

This is an English contract law case about how a contract comes into place through the offer of a reward. More specifically, is the offer deemed to be accepted if the motive of the claimant was something else and not the reward?

Facts of the case (Williams v Carwardine)

The defendant (Mr. Carwardine) had offered a reward of £20 for information leading to the discovery of the murderer of Walter Carwardine, his brother. Leaflets about the reward were distributed in the plaintiff’s area of residence.

Mrs. Williams (the plaintiff) gave information about the incident which eventually led to the conviction of her husband, not so much for reward, but to assuage her feelings.

The plaintiff was apparently aware of the reward, but it was not for getting the cash when she provided the information. She thought she had just a short time to live and that by providing the facts, she could ease her conscience.

The award was later claimed by the claimant. The defendant, on the other hand, refused to pay. He contended that the claimant was motivated by reasons other than the offer when she provided the information. This, he said, implied that no contract existed.

Issue raised

Whether the motive of the plaintiff crucial in deciding that the offer is accepted?

Governing rule behind the case

In general, there isn’t a legally binding contract if someone complies with the requirements for acceptance but is completely unaware of the offer. This might very well happen in a “reward” case. What happens, for instance, if someone gives a dog back without being aware that a reward has been offered for it? Is it necessary to give the award money to the contender? There may or may not be a moral obligation, but in terms of law, the answer is usually no. The act that constitutes acceptance must be done at least in part in response to the offer.

If, on the other hand, a person is aware of an offer, it makes no difference whether the act of acceptance is conducted for motives other than obtaining the reward. This is demonstrated by the case of Williams v Carwardine.

Motive is not essential but knowledge is for the acceptance of an offer.

Judgment of the Court in “Williams v Carwardine”

The Court decided in favor of the claimant. She was allowed to recover the award.

The Court held that if an offer has been accepted with knowledge of the reward that is offered therein, the mere fact that the informer was influenced by motives other than claiming the reward shall be immaterial.

Hence, it was observed that the motives were not relevant.

She had given the information with an awareness of the reward and had therefore made a lawful acceptance of the offer.

The legal point emerging from “Williams v Carwardine”

Responding to an offer with mixed motives can constitute a valid acceptance. Thus, it won’t be unenforceable.

What if there is no knowledge?

The situation will be different if there is absolutely no knowledge of the offer. If a person does not know of an offer, he cannot claim to have accepted it, even if he performs what appears to amount to an acceptance. This was discussed in R. v Clarke (1927).

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