Dickenson v Dodds [1876]

Facts

• The defendant offered to sell his house to the claimant, in an offer open until Friday
• On the Thursday, the defendant accepted an offer from third party
• The defendant asked a friend to tell the claimant that the offer had been revoked, which was done
• The claimant attempted to accept the offer on the Friday

Issue

• Could the claimant seek specific performance; could an offer be revoked by another person under instruction from the offeror

Decision

• Claim dismissed

Reasoning

• There was no consideration provided by the claimant for the defendant to keep the offer open until Friday
• It was acceptable for a friend to revoke the offer on behalf of the defendant
• The offer could be revoked as it not been accepted