ROUTLEDGE v GRANT
An offer can be withdrawn at any time before it has been accepted. Anything said or done to accept the offer after it has been withdrawn has absolutely no effect whatsoever.
Routledge v Grant (1828) 130 ER 920, Best CJ
Grant (defendant) made an offer to rent Routledge's (complainant’s) building. A definitive answer had to be provided to Routledge within the space of six weeks. After three weeks had passed, Grant retracted his offer. However, just within the six-week period, Routledge decided to accept it.
The court held that, in this case, the acceptance had come too late. He reasoned that, if one of the parties had six weeks to accept an offer, the other had six weeks to put an end to it. One party cannot be bound without the other.
Routledge v Grant tell sus a withdrawal usually needs to be communicated to the offeree. This does not become effective until this kind of communication to withdraw is received. The special rule for postal acceptances (below) is not something that applies to withdrawals.
Megan then changes her mind about buying a second hand pair of designer shoes and on Friday leaves Naomi a voicemail. For the entirety of the weekend Naomi’s phone is off and therefore does not listen to the voicemail. Offers can be withdrawn as long as the offer has not been accepted. After an offer is withdrawn nothing can be done or said to accept the offer that is now withdrawn. An offeror can withdraw his offer at any time prior to acceptance. Offers can be withdrawn as long as it has not been accepted. A party is unable to revoke their obligation under a contract once it has been accepted as held in Routledge v Grant (1828) 130 ER 920. There is no revocation here and Megan’s change of mind will have no effect whatsoever.