Powell v. Lee 1908 (Case Summary)

This case is an important decision in contract law that clarified the necessity of proper communication of acceptance to form a binding contract, highlighting the procedural elements necessary to form a binding agreement. It demonstrates that an intention to accept an offer, without proper and authorized communication, cannot lead to a valid contract.

Facts of Powell v Lee

1. The plaintiff, Mr. Powell, applied for the position of headmaster at a school.
2. The school committee decided to appoint him to the role, but the decision was not formally communicated to him.
3. A member of the committee, acting without authority, informed Powell of his selection.
4. Later, the committee changed its decision and appointed someone else, leading Powell to file a lawsuit claiming a breach of contract.

Issues framed

1. Whether there is a binding contract between Powell and the school committee?
2. Whether unauthorized communication of acceptance is sufficient to form a valid contract?

Judgment of Powell v Lee 

The court relied on principles of contract law, emphasizing the requirements of valid communication of acceptance and the authority of the person making the communication.

The court held that for a contract to be binding, acceptance of the offer must be communicated by an authorized person or entity. Since the acceptance was conveyed by an unauthorized member of the committee, it was deemed invalid and not binding on the school committee. The court highlighted that a decision to accept an offer must be communicated officially to form a contract.

The court ruled in favor of the school committee, holding that no contract existed. Mere intention to accept is not sufficient to bind the parties; the acceptance must be communicated effectively and by authorized means.