| Citation | 1913 40 ALJ 489 |
| Date of Judgement | April 17, 1913 |
| Case Type | Based on the validity of the contract under the Indian Contract Act |
| Case No | Civ.Rev.NO 10 of 1913 |
| Plaintiff | Lalman Shukla |
| Defendant | Gauri Dutt |
| Court | Allahabad High Court |
| Bench | Justice Banerjee |
INTRODUCTION
Contracts are an essential part of our lives. Unknowingly, we engage in several contracts in our daily lives. Contracts are beneficial for business, commercial, and transactional purposes. It can be expressed or implied. Contracts dealt with under the INDIAN CONTRACT ACT, 1872 in India. Lalman Shukla v Gauri Datt is one of the Landmark cases that deals with the validity of a contract if there exists no acceptance. It explains the essentials or requisites of a valid contract and section 3 of the Contract Act, of 1872 which is about the communication of a proposal. This case mainly deals with general offers and communication proposals. In this case, it was highlighted that the most important thing to convert an offer into a contract is to understand and accept the offer. Second, the parties accepting the offer must understand the offer in order to complete the contract.
FACTS OF THE CASE
In this case, the defendant Gauri Dutta’s Nephew absconded from her house. The hint of the boy could nowhere be found. After the defendant became aware of the same, Gauri Dutt, shipped all the servants in search of her missing nephew, and out of all the servants was the plaintiff, Lalman Shukla who had additionally long gone out in search of her nephew. Lalman Shukla had left the house and was sent to Haridwar from Kanpur and was equipped with money and other costs for his railway fare. As soon as Lalman Shukla left the residence Gauri Dutt made an announcement that any person who will trace and discover his missing Nephew would be rewarded with an amount of Rs 501. Lalman Shukla had no knowledge about it before he went to trace the missing boy. He had no idea that such an announcement was made in his absence.
Lalman Shukla traced the boy and brought him back to his home. Six months after the incident occurred plaintiff, Lalman Shukla was removed from the job. After understanding the offer Lalman Shukla claimed the money from his master Gauri Dutt but she denied paying the praise of Rs 501 to him. As a result, Lalman Shukla filed a case against Gauri Dutt, his master, for not giving him the reward for the performance of his act.
ISSUE RAISED
- Whether there existed a valid contract
- Whether Lalman Shukla was entitled to get the reward for the performance of his act
CONTENTIONS
Plaintiffs Argument:
Lalman Shukla, the plaintiff, vehemently asserted that his mere performance of finding the missing boy was pretty much enough for him to claim the reward Since whoever located the lost child and brought him back, might acquire the reward in accordance with Gauri Dutt’s condition. As a result, the plaintiff had located the lost boy and took him in accordance with the defendant’s requirement.
He stated that it was not important to have a piece of prior knowledge about the reward as it was a general offer for everyone. According to him, there was no need for the specific terms of the offer to be communicated for the contract to be considered complete.
Defendants Argument:
The formation of an agreement depends on the acceptance of the offer. If the petitioner did not know about the offer, there could be no valid acceptance. In Lalman Shukla vs. Gauri Dutt, the Plaintiff had no awareness of the reward offered by the defendant because the handbill was released after the Plaintiff had already set out to find the defendant’s nephew.
The plaintiff came to know about the offer after it had been declared through the respondent as a result the plaintiff had no possibility to just accept the offer. So, in line with the defendant Gauri Dutt Lalman Shukla is no longer entitled to get the praise and consequently, he can’t claim it.
JUDGEMENT
In the case of Lalman Shukla vs. Gauri Dutt, the Allahabad High Court dismissed and brushed off the petitioner’s appeal against the respondent, Gauri Dutt. The court examined all of the information of the case and concluded that for a valid agreement to be formed, there has to be knowledge and assent to the offeree made by the proposer, or approval by the offeree is important earlier than an agreement may be considered binding.
Here, the plaintiff no longer knows the reward before performing his act. He got to know about it much later, in which case there was no possibility of accepting it, hence there was no agreement Therefore, Lalman Shukla became not entitled to get or claim the praise.
The choice reiterated that the plaintiff was just satisfying his responsibilities as a servant of tracing the missing boy which was a part of his obligation. consequently, the plaintiff’s suit against the defendant was completely dismissed by the court.
CONCLUSION
The overall conclusion of the case is that the offer made by the defendant Gauri Dutt was a general offer made to everyone and whoever did it would be rewarded for the same. This judgment lays down a clarity of acceptance for a general offer. For an offer to become a contract knowing the offer, communication, and assent are very important factors in general offers. If there is no prior knowledge about the offer or if there is no assent to the offer made, there is no contract, Hence the plaintiff cannot claim the reward in return. In this case, Lalman Shukla even though performed his duty, was not aware of the offer announced earlier in his absence and hence was not entitled to claim the reward. This case clearly explains the essentials of the contract and this Indian contract act
REFERENCES
https://www.lawctopus.com/academike/lalman-gauri-ica/
https://lawbhoomi.com/lalman-shukla-vs-gauri-dutt/#Judgement_of_the_Case_Lalman_Shukla_vs_Gauri_Dutt
This Article is written by Tanya Baweja Of Maharaja Agrasen Institute Of Management Studies, Intern at Legal Vidhya.
