ABSTRACT
It now seems established that revocation cannot take place if the offeree has started to perform. In Errington v Errington (1952), a father promised his daughter and sonin-law that, if they paid off the mortgage on a house he owned, he would give it to them. The young couple duly paid the instalments, but the offer was withdrawn shortly before the whole debt was paid. Held – there was an implied term in the offer that it was irrevocable once performance had begun. This is also supported by dicta in Daulia v Four Millbank Nominees (1978).
