Williams v Carwardine [1833] EWHC KB J44 (22 March 1833)

The plaintiff gave information leading to the conviction of murderers after being severely beaten and fearing death. Despite her motive being conscience rather than the advertised £20 reward, the court held she was entitled to recover as she had fulfilled the conditions of the offer.

Facts

Walter Carwardine was murdered in March 1831, and his body was found in the river Wye in April 1831. The defendant, William Carwardine (the victim’s brother), published a handbill offering a £20 reward to anyone who would give information leading to the discovery of the murderer, with conviction being required before payment.

The plaintiff, Mary Anne Williams, initially gave a deposition in April 1831 that differed substantially from her later account. After being severely beaten by William Williams (one of the murderers) and believing she would not recover, she made a second, more detailed voluntary statement in August 1831, confessing she had witnessed the murder. This disclosure led to the conviction of Joseph Pugh, William Williams, and John Matthews at the Hereford Assizes in March 1832.

Issues

The key issue was whether the plaintiff was entitled to the reward when her motive for giving information was not the promise of reward contained in the handbill, but rather her troubled conscience and belief that she was dying.

Defendant’s Argument

The defendant argued that since the plaintiff did not give the information in consequence of the handbill or for the sake of the £20 reward, but from other motives entirely, there was no contract between the parties. The handbill was published in April but disclosure was not made until August, and was motivated by the plaintiff’s conscience rather than the reward.

Judgment

Mr Justice J. Parke ruled in favour of the plaintiff. The court held that if the plaintiff came within the conditions of the handbill, she was entitled to the reward regardless of her motive for providing the information.

The judge stated during the trial that the terms of the handbill were that whoever would give information leading to a discovery would receive the reward on conviction. The jury found that the plaintiff gave the information which led to the discovery of the murderers, but that she did not give that information for the sake of the £20 reward, nor in consequence of the handbill, but from stings of conscience.

Despite this finding regarding motive, Mr Justice J. Parke directed that the plaintiff was entitled to recover, stating that motive was not material and that if she came within the terms of the handbill, that was sufficient.

Verdict was entered for the plaintiff with damages of £20.

Implications

This case established an important principle in contract law regarding unilateral contracts and rewards. The decision confirms that where an offer of reward is made to the public, a claimant who performs the required act is entitled to the reward regardless of their subjective motivation. The court focuses on objective performance of the conditions rather than the offeree’s knowledge of or motivation by the offer.

The case is significant in distinguishing between the performance of conditions attached to an offer and the motive for that performance, establishing that compliance with the terms of an offer is sufficient to create a binding contract, even where the offeree acted for entirely different reasons.

Verdict: Verdict for the plaintiff with damages of £20. The defendant was given leave to move to enter a nonsuit, but the plaintiff’s claim succeeded on the basis that she fulfilled the conditions of the reward offer regardless of her motive.

Source: Williams v Carwardine [1833] EWHC KB J44 (22 March 1833)