Case name - Lalman Shukla v. Gauri Dutt
Citation - 1913 40 ALJ 489
The case Lalman Shukla v. Gauri Dutt case is one of the popular landmark judgments which is based on the validity of a contract under the Indian Contract Act. The case was filed in the Allahabad High Court in 1913 the verdict was given by the Chief Justice of Allahabad High Court J. Banerjee.
FACTS OF THE CASE
In this case, the defendant Gauri Dutta’s Nephew absconded from his house. The trace of the boy was not found. After the incident, Gauri Dutt the defendant sent all his servants in search of her missing nephew and out of the servants was the plaintiff Lalman Shukla who had also gone to find the boy and bring him back.
After Lalman was sent to Haridwar from Kanpur. He was provided with money and other expenses for his railway fare. As soon as Lalman left the house Gauri Dutt made an announcement that any person who traced and found his missing nephew would be rewarded with money of Rs 501. Lalman Shukla had no idea and was not aware of the fact. He had no knowledge about it before he went to trace the missing boy. Then Lalman traced the boy and brought the boy back to Kanpur. After knowing about the reward Lalman claimed the money from his master Gauri Dutt. But Gauri Dutt denied paying the reward of Rs 501 to him. As a result, the plaintiff Lalman Shukla filed a case against Gauri Dutt his master for not giving him the reward as he is not entitled to recover for the performance of his act.
ISSUES OF THE CASE
Whether Lalman Shukla entitled to get the reward money for searching missing nephew?
Whether there was a valid acceptance between the two parties?
Whether there was a contractual relationship between the two parties?
CONTENTIONS OF THE PARTIES
Petitioner (Lalman Shukla) vehemently contended that he was entitled to receive the reward money from Respondent (Gauri Dutt) as he found the missing nephew. Petitioner stated that there is no need for prior knowledge emphasizing Section 8 of the Indian Contract Act 1872 which states, “Performance of the act or the acceptance of any consideration in a proposal is the acceptance of the proposal”, and to have the knowledge of the condition was immaterial.
The defendant strongly argued that the plaintiff had no knowledge about the offer and was not aware of it before finding the missing nephew. So an offer without the knowledge of the offeree cannot be accepted or there is no such condition where the plaintiff can accept the offer without its knowledge. Gauri Dutt emphasized Section 2(a) which said, “When one person signifies to another his willingness to do or to abstain from doing anything, with a view to obtaining the assent of that other to such act or abstinence, he is said to make a proposal”. Further Section 2(b) said, “When the person to whom the proposal is made signifies his assent thereto, the proposal is said to be accepted. A proposal, when accepted, becomes a promise”. Therefore, the plaintiff had no knowledge about the offer made and there was no acceptance. So according to Section 2(h) of the Indian Contract Act 1872, since there was no acceptance, there was no agreement to be enforced by a court of law.
The case was filed in the Allahabad High Court and was presided over by Justice Banerji at the Allahabad High Court. In this case, it is derived that two aspects need to be fulfilled:
To have complete knowledge of the offer or the proposal
Acceptance of the offer
In this case, the petitioner's appeal against the respondent Gauri Dutt was dismissed by the court. After analysing all the facts of the case, it was held by the Court that for creating or entering into a valid contract there has to be knowledge and assent to the offer being made by the proposer. There has to be proper acceptance or the offeree must give his approval before accepting which was absent in the present case.
The plaintiff had no knowledge about the reward before performing his act. He came to know afterwards that there was no possibility of accepting the offer. Hence there exists no contract so as a result the court came to the decision that the appellant Lalman Shukla was not entitled to get the reward. without having any prior knowledge and information about the facts which restricts him from claiming the reward.
The judge said that Lalman Shukla was fulfilling his obligations as a servant of tracing the missing boy. It was a part of his duty which he was merely doing. Hence his suit against the defendant was entirely dismissed by the court as there was no contract between both the parties.