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    BlogNews & JudgementCase Law: Lalman Shukla Vs. Gauri Dutta - Complete Summary Here

    Case Law: Lalman Shukla Vs. Gauri Dutta – Complete Summary Here

    Lalman Shukla Vs. Gauri Dutta

    Through the segments of the Indian Contract Act, 1872, the simple execution of the imperatives of an offer establishes an acceptance. And sets out the establishment for a substantial agreement I.e. valid contract. This provision nonetheless, fails to cover and neglects some important:

    • Information on the offer
    • Goal to enter a legitimate relationship
    • The intention behind the entering into an agreement.

    Also, just because the aforementioned components were perused together, guaranteeing a more useful understanding and utilization of a valid acceptance later on, in this case.

    The Honorable High Court of Allahabad; nicely explained these facts that are discussed by this comprehensive case brief.

    Case story and facts:-

    Defendant, Gauri Dutt’s nephew absconded suddenly from home and the offended party. The plaintiff, Lalman Shukla, the munim, and one among the various workers were directed to seek after the kid. As required, with the necessary money amount for the tickets of railways and other travel expenses. The Lalman Shukla left for finding the kid in Hardwar. Afterward, the litigant declared a compensation of Rs. 501 to any individual who will discover his nephew.
    Meanwhile, the servant, the plaintiff is on his way to follow the kid at Rishikesh. He also informed the litigant about his nephew’s security. And took the kid back with him to Cawnpore. The offended party was properly rewarded with 2 sovereigns for traveling to Hardwar and Rs. 20 on returning home. For the following a half year, the Lalman Shukla served the respondent. But after that he was dismissed from his job, he brought a suit. He claimed over the rest of the sum, that was declared by his ex-master for one who will find his nephew. The sum of Rs. 499/- was demanded by him.

    But his claim was dismissed by the Lower Court. The aggrieved party i.e. the plaintiff (Here, as the Appellant) filed an appeal in Honorable High Court of Allahabad.


    The issues raised in the Honorable court are discussed below:-

    The current case fundamentally spins around one single issue, which is the very question of this case:
    Whether there was a valid acceptance to the offer made?


    • Appellant: The Learned Counsel for the appellant affirmed that the privity of contract was inconsequential and both motive and knowledge were purposeless. This was declared by depending upon the accompanying decisions:
    • Williams V. Carwardine: – There exists a legitimate agreement when the offer is acknowledged on achieving the ineluctable conditions involved by the proposer through his proposal.
    • Gibbons V. Proctor: – The Honorable Divisional Court held that if an individual plays out specific terms of an offer. Totally unconscious about the prize on completion of its essentials is bound by the award.

    In this manner, it was battled that the acknowledgment of the considerable number of terms. And states of the offer entitle the litigant for making sure about the award being in question.

    Defendant: The Learned Counsel for the litigant asked that the offended party’s case must be kept up. As the issue on basis of contract which doesn’t exist. Since there was no acknowledgment of the said offer, there was no legally enforceable agreement between the parties. Additionally, the offended party was obliged to discover the nephew. That’s he was not qualified to claim any sum of money.
    These conflicts offered an extraordinary conversation starter, for the Indian Judiciary to determine. As for English comprehension of Contract Law and the Indian Society.


    After analyzing the facts of the case carefully, along with the authorities cited and arguments advanced. The Honorable High Court affirmed the decision of the Lower Court, asserting that the current case must be built up through a contract. Similarly, it held that no acceptance could be made. Because the acceptor had no knowledge of the offer. On such terms, no contract can be stimulated. The truth is that at every moment the munim was ready to go all the way to Hardwar. In order to search the missing boy and to complete this task. In summation, the Judge announced that there was a subsisting commitment. And the completion of terms and conditions of this offer without any earlier information restricts the plaintiff I.e. Lalman Shukla from enjoying an award for its work.

    Investigation & Analysis:-

    According to Section 10 of the Indian Contract Act, 1872. It is built up that the essential segment of a legitimate agreement is the lawful aim to enter one and perform its commitments. Applying this in the current case, the required intention to enter an agreement was missing with respect to the offended party. I.e Lalman Shukla to play out his legitimate commitments as he was assigned the task by the litigant to find the absconded nephew. Plus, there was no substantial acknowledgment since the litigant had no information on this offer. And applying the method of reasoning declared in Ramchandra Chintaman V. Kalu Raju, he was at that point under an obligation to discover the kid and couldn’t guarantee the reward, on its completion. Also, on deciphering the decision disclosed in Carlill V. Carbolic Smoke Ball concerning the current case. The absence of prior knowledge of the offer and a legitimate acceptance to it also dismissed their claim on the reward.

    Accordingly, by pointing out these restrictions with respect to the appealing party to give a valid acceptance. The Honorable High Court played a significant role in rethinking the attributes of obligations. A lawful commitment and a legal binding in the contractual world. And as I would see it, has legitimately recognized the two.


    This case projected light on the important term and explanation of the General offer. This was made to people in general on the large not to any individual specifically. As per this feature, acknowledgment of an offer, need not be communicated to one offering that. Mere fulfilling its required conditions is enough to make one eligible. He can enjoy the reward or compensation as promised on completion.

    Thus the offer, in this case, is a general offer.

    While declaring the significance of both intention to enter a contract. And having the information on the offer before conveying their acceptance. It was daring with respect to the Judge to conflict with the setup judgment in the English Law. This decision declared the Indian understanding and way of interpretation of contractual law. Other than concurring with other importances, which enhanced the term Acceptance.

    Points to Remember in Lalman Shukla Vs. Gauri Dutta

    The High Court dismissed the revision application upholding the Judgement & Order of the Judge of the Court of Small Causes at Cawnpore in favour of the Defendant-Respondent.

    1. There must be an intention to create legal relations between parties.
    2. An offer may be expressed or implied.
    3. The terms of the offer must be certain and not vague.
    4. Silence cannot be explained as valid consent.
    5. An offer must be made to obtain the consent of the other.
    6. It must be communicated by proper means.
    7. Two identical cross offers do not result in a contract.
    8. An offer is different from an invitation to offer.
    9. An offer may be general or specific as explained in this case.

    Read another interesting Article: Leading Lawyers and Justice from Non-NLU

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