ABSTRACT
The significance of a case is often less a matter of what it determined than of what subsequent courts took it to mean. The case of Adams v Lindsell is a remarkable illustration of such a maxim.2 The decision concerned a misdirected letter of offer. The judgment is a brief paragraph in length and it determines that the offer cannot be withdrawn after it has been accepted. It is a sparsely reasoned judgment and it was ignored for some 30 years. It was taken up first, and in different circumstances, in an appeal from a Scottish Court of Sessions decision3 and then was interpreted, both in the United States4 and in England,5 as determining that a postal acceptance is binding once it is placed in the post.
