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

The defendant offered a £20 reward for information leading to the discovery of his brother's murderer. The claimant provided the information, motivated by a desire to ease her conscience while believing she was dying, and successfully claimed the reward.

Facts

In April 1831, the defendant, Mr William Carwardine, published a handbill offering a reward of £20 to any person who would provide information that would lead to the discovery of the murderer of his brother, Walter Carwardine. The plaintiff, Mary Anne Williams, was aware of the offer. In August 1831, the plaintiff, having been beaten and bruised by a man named Williams, believed herself to be on her deathbed. To ‘ease her conscience’, she gave a voluntary statement to a magistrate which contained information that led to the conviction of Williams for the murder of Walter Carwardine. At the trial for the reward, the jury found that the plaintiff had given the information not for the reward, but to appease her conscience. The judge directed a verdict for the plaintiff, but gave the defendant leave to move to enter a nonsuit.

Issues

The central legal issue was whether the plaintiff’s motive for providing the information was relevant to her ability to accept the unilateral offer made by the defendant. Specifically, could a person who performs the condition of a unilateral offer (providing information), while being aware of the offer, successfully claim the reward even if their primary motive for performance was not to obtain the reward?

Judgment

The Court of King’s Bench held unanimously that the plaintiff was entitled to the reward, as her motive for providing the information was irrelevant. The performance of the condition was sufficient to constitute acceptance of the unilateral offer.

Lord Denman C.J.

Chief Justice Denman held that the plaintiff had fulfilled the terms of the offer, and any inquiry into her motives was unnecessary. He stated:

The plaintiff, by having given information which led to the conviction of the murderer of Walter Carwardine, has brought herself within the terms of the advertisement, and therefore is entitled to recover.

Littledale J.

Justice Littledale agreed, emphasising the public and general nature of the offer. He dismissed the relevance of the plaintiff’s private feelings:

The advertisement amounts to a general promise, to give a sum of money to any person who shall give information which might lead to the discovery of the offender. The plaintiff gave that information. The jury find that she was induced by other motives: but I think that is not material. If the party comes within the terms of the contract, she is entitled to the reward.

Parke J.

Justice Parke concurred, highlighting the formation of a contract upon performance of the conditions specified in the advertisement. He concisely noted:

There was a contract with any person who performed the condition mentioned in the advertisement.

Patteson J.

Justice Patteson also agreed that the plaintiff’s motives were not a matter for the court to consider, stating:

We cannot go into the plaintiff’s motives.

Implications

The decision in Williams v Carwardine is a foundational authority in English contract law on the subject of unilateral contracts. It establishes the key principle that provided an offeree knows of an offer and performs the conditions of that offer, a legally binding contract is formed. The court’s critical reasoning was that the advertisement was a public promise open to anyone, and the plaintiff’s performance of the stipulated act (giving the information) constituted acceptance. The case clearly separates the act of acceptance from the motive for that act. This principle clarifies that in reward cases, the subjective intention of the person performing the act is irrelevant, as long as the act itself corresponds to the terms of the offer. It remains a crucial case for understanding acceptance in the context of public and reward-based offers.

Verdict: The court discharged the rule to enter a nonsuit, thereby upholding the original verdict in favour of the plaintiff. The plaintiff was entitled to recover the £20 reward.

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