Lalman

Shukla vs
Gauri Dutt
1913
Contents

1. Facts of Lalman Shukla vs Gauri Dutt

2. Issues Raised in Lalman Shukla vs Gauri Dutt
3. Arguments by Plaintiff
4. Arguments by Defendant
5. Concepts of Contract Law Referred
6. Ratio Decidendi
7. Judgement of the Case: Lalman Shukla vs.
Gauri Dutt
8. Lalman Shukla vs Gauri Dutt Summary
Facts of Lalman Shukla
vs Gauri Dutt
The case of Lalman Shukla vs. Gauri Dutt was heard in the Allahabad
High Court, as the Plaintiff’s claims were rejected in the lower court. In
this case, the defendant’s nephew left home without anyone knowing,
and efforts were made to find him. The defendant sent his servants to
various places, including Haridwar, to search for his missing nephew.
The defendant provided money for their travel expenses, but the
servants used it for other things instead

The Plaintiff worked as a clerk for the defendant’s firm, and he was
sent to Haridwar to find the defendant’s nephew. While the Plaintiff
was searching for the nephew, the defendant distributed handbills
offering a reward of Rs. 501 to anyone who could locate and bring
back his nephew. Fortunately, the Plaintiff found the nephew in
Haridwar and promptly informed the defendant. He then brought
the nephew back to Cawnpore
 Facts of Lalman Shukla
vs Gauri Dutt

As a reward for his successful efforts, the defendant gave the

Plaintiff two sovereigns and twenty rupees. The Plaintiff was
content with the reward and resumed his usual work.
However, six months later, the defendant dismissed the Plaintiff
from his job due to a disagreement. After being let go, Plaintiff
claimed that he was still owed Rs. 499 as part of the promised
reward for finding the defendant’s nephew. According to the
Plaintiff, before he left for Haridwar, the defendant had promised
him expenses and other gifts and assured him of the Rs. 501
reward.
 Issues Raised in Lalman
Shukla vs Gauri Dutt

The issues raised in Lalman Shukla v Gauri Dutt were:

Whether the decision given by the lower court is valid?

What kind of offer did the defendant claim to have made?

Can the act of the Plaintiff be termed as a valid acceptance of

the offer made by the defendant?

Is this a valid contract?

Should the reward of Rs. 499 claimed by the Plaintiff be

provided?
Arguments by Plaintiff

In Lalman Shukla vs Gauri Dutt, the Plaintiff argued that by

performing the essential task of finding the defendant’s nephew, he
had effectively accepted the general offer made by the defendant.
According to Plaintiff, there was no need for the specific terms of the
offer to be communicated to him for the contract to be considered
complete. They also claimed that the handbill containing the offer
was sent to them

The Plaintiff in Lalman Shukla vs Gauri Dutt also referred to two

important legal cases to support their position. In the case of
Gibbons v. Proctor, a Superintendent of Police had offered a reward
to anyone providing information about a criminal. A police officer,
unaware of the reward, provided valuable information to the
Superintendent through a third party. However, before the
information reached the Superintendent, the police officer learned
about the reward and claimed it. The court ruled in favour of the
police officer, establishing the principle that an offer can be accepted
even without direct knowledge of it.
Arguments by Defendant

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 defendant relied on the precedent set by the case of Fitch v.

Snedeker, where the main issue was finding the suspect or culprit of a
murder. Fitch came forward and provided information that led to
identifying the culprit. The Governor had offered a reward to anyone who
could provide such information. However, Fitch was unaware of the
reward when he provided the information to the police. He became aware
of the reward only after giving the information and subsequently filed a
suit to claim it. Nevertheless, in that case, the court ruled that there can be
no acceptance of an offer without knowledge of it.

In light of this precedent, the defendant argued in Lalman Shukla v Gauri

Dutt that since Plaintiff did not know the reward when performing the
task, there could be no valid acceptance of the offer
Concepts of Contract Law
Referred
Laws and concepts which were considered in
Lalman Shukla versus Gauri Dutt case are:

Offer;
General offer;
When communication of the
general offer is completed;
Acceptance;
Implied acceptance under section 8;
Agreement.
Ratio Decidendi

In the Lalman Shukla vs. Gauri Dutt case, two essential elements are
required to form a valid contract between two parties:

Complete knowledge of the offer or proposal: The person to

whom the offer is made (the offeree) must be aware of all the
details and terms of the proposal.

Acceptance of the offer: The offeree must agree to the proposal

and communicate their acceptance to the offeror.
Judgement of the Case:
Lalman Shukla vs. Gauri Dutt
In the case of Lalman Shukla vs Gauri Dutt, the Allahabad High Court
dismissed the petitioner’s appeal against the respondent, Gauri Dutt. The
court thoroughly examined all the facts of the case and concluded that
for a valid contract to be formed, there must be both knowledge and
assent to the offer made by the proposer. Proper acceptance or approval
by the offeree is necessary before a contract can be considered binding.

Further, in Lalman Shukla versus Gauri Dutt, the Plaintiff, Lalman Shukla,
did not know the reward before he performed his task of searching for
the missing boy. He only became aware of the reward afterward, which
made it impossible for him to accept the offer in the first place. As a
result, there was no valid contract between the parties, and the court
ruled that the appellant, Lalman Shukla, was not entitled to claim the
reward due to the lack of prior knowledge and information about the
offer.

The judge pointed out that Lalman Shukla was merely fulfilling his duties as a servant by
tracing the missing boy. It was a part of his obligation, and he was not doing it in response
to the reward offer. Therefore, the court completely dismissed the Plaintiff’s lawsuit
against the defendant in Lalman Shukla v. Gauri Dutt since there was no valid contract
between the parties
 Lalman Shukla vs Gauri
Dutt Summary
In the case of Lalman Shukla v. Gauri Dutt, the Plaintiff, Lalman Shukla,
appealed against the defendant, Gauri Dutt, claiming a reward for
finding Gauri Dutt’s missing nephew. However, the court dismissed the
appeal, stating that for a valid contract to exist, there must be both
knowledge and consent to the offer. In this case, Lalman Shukla had no
prior knowledge of the reward before he performed the task of
searching for the boy.

Consequently, he could not have accepted the offer. As a result, the

court concluded that there was no valid contract between the parties,
and Lalman Shukla was not entitled to the reward. The court
emphasised that Lalman Shukla was merely fulfilling his duties as a
servant, and there was no contractual agreement for the reward.
Thank You
ANMOL SINGH
23GSOB2010874