September 07, 2006
Where Dickinson's Agent Met Dodds
Speaking of old contract law chestnuts, how about Dickinson v. Dodds? In the case, one Dodds made a written offer to one Dickinson, to sell certain dwelling-houses and property at Croft (a village near Darlington in Yorkshire) for £ 800, "[t]his offer to be left open until Friday, 9 o'clock a.m., 12th June 1874." Before that time expired, Dickinson learned that Dodds was apparently also offering to sell it to one Allan. Dickinson tried to accept the offer, and his agent Berry finally managed to run Dodds down in the Darlington railway station and hand him the written acceptance two hours before the deadline, at 7:00 a.m. Friday morning. Dodds refused to sell him the property, saying that he had already sold it to Allan.
The questions for the court were (1) are offers unsupported by consideration revocable at will, even when the offeror has stated that it will be held open for a specific period? and (2) was Dodds's offer somehow revoked before Dickinson delivered the acceptance? Held: Yes and yes. The former ruling became black letter law, but the latter is still a little controversial.
The present Darlington Railway Station, with a fine Victorian clock tower, dates only from 1887, a half-dozen years after the case. The actual building where Dickinson's agent confronted Dodds is the old station, now known as the "North Road" station, shown in the accompanying picture. It's now the site of the Darlington Railway Centre and Museum. The story is that the Stockton & Darlington Railway built the new station because Queen Victoria visited the old one and found it shabby.
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