Facts
- The case concerned a dispute over the attempted sale of a horse between Mr. Paul Felthouse (uncle) and his nephew, Mr. John Felthouse.
- Mr. Felthouse wrote to his nephew: "If I hear no more about him, I consider the horse mine at £30 15s," seeking to bind the nephew's silence as acceptance.
- The nephew did not reply to the uncle's letter.
- The nephew intended to sell the horse to his uncle and instructed an auctioneer, Mr. Bindley, to exclude it from an auction.
- The auctioneer accidentally sold the horse at auction to a third party.
- The uncle sued the auctioneer for conversion, claiming he had legal title to the horse, asserting there had been a contract of sale.
- The central issue was whether the nephew’s silence in response to the uncle’s letter created a binding contract.
Issues
- Whether an offeree's silence can constitute valid acceptance of a contractual offer.
- Whether a contract of sale existed between the uncle and nephew such that the uncle held legal title to the horse.
- Whether the unilateral imposition that silence would amount to acceptance is effective in contract formation.
Decision
- The Court of Common Pleas ruled against the plaintiff (uncle), finding that no contract had been formed.
- The court held that acceptance of an offer must be explicitly communicated to the offeror; silence does not amount to acceptance.
- The uncle's attempt to stipulate that silence would be treated as acceptance was deemed legally invalid.
- The nephew’s internal intention to sell the horse was not communicated to the uncle and did not satisfy the requirements of acceptance.
- No legal title passed to the uncle, so he could not succeed in the action for conversion.
Legal Principles
- Silence cannot constitute acceptance; a valid contract requires clear expression or communication of assent by the offeree.
- An offeror cannot unilaterally impose contractual liability on an offeree by stipulating that silence will amount to acceptance.
- Contract formation is grounded in mutual assent, which must be demonstrably communicated between parties.
- Although mere silence is insufficient, unequivocal conduct may amount to acceptance in other circumstances, but no such conduct was present here.
- The judgment reinforced the necessity of clear and certain communication in contract formation to prevent unfairness and ambiguity.
Conclusion
Felthouse v Bindley definitively established in English contract law that silence cannot be deemed acceptance of an offer, requiring express communication or unmistakable conduct evidencing agreement for a binding contract to arise.