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Dickinson v. Dodds

L.R. 2 Ch. D. 463, 2 Ch. Div. 463 (1876)

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Dickinson v. Dodds

Court of Appeal, Chancery Division

L.R. 2 Ch. D. 463, 2 Ch. Div. 463 (1876)

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Facts

On June 10, 1874, John Dodds (defendant) drafted a documented which stated his willingness to sell a piece of property to George Dickinson (plaintiff). The document stated that the offer would be open until 9AM on June 12, 1874. On Thursday, June 11, Dickinson was informed by his agent that Dodds changed his mind and actually intended to sell the property to Thomas Allen (defendant). Dickinson immediately went to the home of Dodd’s mother-in-law where Dodds was staying and dropped off a document expressing his intent to accept Dodds’ offer to sell the property. Dodds never received this document from his mother-in-law. At 7AM on the morning of June 12, Dickinson and his agent both found Dodds at a train station and provided him with duplicate copies of the document accepting Dodds’ offer to sell. Dodds stated that it was too late and he had already sold the property to Allen. Dickinson brought suit against Dodds and Allen seeking specific performance of Dodd’s offer to sell the property to him. The Vice Chancellor heard the case and held for Dickinson, granting specific performance. Both Dodds and Allen appealed.

Rule of Law

Issue

Holding and Reasoning (James, L.J.)

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Questions and answers

Offers vs Contracts

So if Dickinson /hadn't/ heard about Dodd's offer to Allen and still attempted to buy the property, would he have had a more defensible case?

I'm also a bit confused as to the difference between 'contract' and 'offer'. Dodd's letter to Dickinson doesn't read like an offer (ex. "Hey, if you want to buy this property, here's the cost...") but rather, as a definitive agreement ("I hereby AGREE to sell to Mr. George Dickinson..."). Dickinson has, in writing, an agreement that Dodd intended to sell the property to him, provided he give acceptance by a certain deadline, which he did. How is this not enforceable? What does a 'meeting of the minds' have to do with an objectively expressed and mutually-agreed upon contract?

Thanks advance for any help you're able to give.

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