extra notes on revocation

An offer can be terminated in two ways:
- Express Revocation: The offer is clearly revoked by the offeror.
- Implied Revocation: Can occur through actions like making a counter-offer or a second differing offer.
  - Case Reference: Hyde v Wrench (1840) shows that a counter-offer implies rejection of the initial offer.
Revocation may also be implied when the offeror makes a second offer without revoking the first. - Case Reference: Pickfords Ltd U Celestica Ltd [2003] establishes that a second offer can imply revocation if there is clear intention to withdraw the first. - If a second quotation is requested as an option (not as a counter-offer), both offers remain open for choice.

In a bilateral contract, the offeror can withdraw the offer anytime before acceptance. - Case Reference: Offord U Davies (1862) supports the notion that revocation after acceptance is ineffective.

An offer may be stated as 'open' for a specific period but this does not prevent its revocation after that period unless supported by consideration.
Such a promise to keep an offer open for a period is a pre-contractual promise and is unenforceable without consideration. - Case Reference: Routledge v Grant (1828) demonstrates the unenforceability of such promises.
The court held that the defendant's revocation during the 'open' period was valid due to lack of consideration.

The distinction around firm offers is not mirrored in most legal systems, including many US states.
Comparative References: US UCC § 2-205 prevents revocation during a fixed acceptance time period, similar to rules in PICC and PECL.
Reform discussions include the possibility of allowing small reciprocal benefits to support firm offers as in Williams v Roffey Bros. & Nicholls (Contractors) Ltd.
Reforms could potentially align English law with those principles found in other jurisdictions regarding firm offers.

Revocation is ineffective until communicated to the offeree; the offer remains open until such communication occurs.

Postal rules apply to acceptances but not to revocations, affecting timing significance in communications.
Case Reference: Byrne and Co. v Van Tienhoven and Co. (1880) illustrates that acceptance may occur even after a revocation letter is sent but not received.
Case Reference: Henthorn v Fraser (1892) shows that an acceptance posted before a revocation is valid upon dispatch.

Special rules exist for revocations of unilateral offers made to the public, where personal communication of revocation is impractical. - Case Reference: Shuey v United States (1875) addresses this type of revocation, focusing on unidentified offerees.

Revocation need not be directly from the offeror if the offeree reasonably believes the information. - Case Reference: Dickinson V Dodds (1876) shows that offerees may learn about revocation through other reliable sources, even if the communication isn’t authorized by the offeror.
Offerees should verify revocation claims to mitigate risks of misinformation.