Does the Postal Rule Apply to Revocations?
In Byrne & Co. v. Van Tienhoven & Co. (1880), the courts confirmed the long-standing idea that any revocation of an offer must be communicated to the offeree; although again there are some exceptions to this rule. The offeror need to communicate this revocation to the offeree himself, however. It is not always practicable for a company, or even an individual, to communicate directly with the other contracting party and this is reflected in the decision in Dickinson v. Dodds (1876) that revocation may be communicated by a reliable third party. The question is then whether a revocation sent at the same time as an acceptance will nullify an offer. In Household Fire and Carriage Accident Insurance Co. v. Grant (1879), the court ruled that the postal rule only applies to acceptances. As a result, revocation is only effective if it can be received by the offeree before they post their acceptance. In contract law, the offeror is aware of the terms of an offer before the offeree and thus is in
