Introduction
Contract law sets out binding agreements between parties. In reward cases, one party makes a public offer that others accept by completing a specific task. Gibbons v Proctor (1891) 64 LT 594 remains important for showing how acceptance works in such cases. This decision confirms that claimants must prove they knew of the reward and met its exact terms when acting. This links the action directly to the reward offer.
The Facts of Gibbons v Proctor
A police superintendent offered payment for information leading to an arrest. Officer Gibbons obtained the details before hearing about the reward but learned of it before passing the information to his superior. The court decided Gibbons met the acceptance requirements and awarded him the reward.
Awareness of the Reward: Key Terms
This case shows claimants must know of a reward before acting. Doing the requested task counts as acceptance only if done because of the reward offer. This separates unilateral contracts from two-party agreements. The court supported Gibbons' claim because he knew of the reward before finishing the required task.
Accepting Unilateral Contracts
In unilateral contracts, acceptance happens by doing the act - not through direct communication. Finishing the act works as both acceptance and performance. Gibbons v Proctor illustrates this: giving information while aware of the reward met both terms.
Comparing Gibbons v Proctor with R v Clarke (1927) 40 CLR 227
R v Clarke involved a different scenario. Clarke gave information to avoid blame, not to claim a reward. Australian courts dismissed his claim because his actions were unrelated to the offer. This difference highlights why acting because of the reward matters.
Gibbons v Proctor's Impact on Later Law
This case is still widely referenced in reward contract disputes. It helped shape rules about offers and acceptance in unilateral contracts. Its focus on knowing about the reward before acting has guided courts in similar cases.
Conclusion
Gibbons v Proctor (1891) 64 LT 594 clarifies rules for rewards in unilateral contracts. It requires knowing about the reward before finishing the task. Comparing it with R v Clarke shows why acting due to the offer is needed. The case continues to guide how courts apply contract rules to reward claims, keeping clear standards for valid cases.
