The case of Williams v Carwardine is a landmark English contract law decision that clarified the enforceability of reward offers made to the public. It established the important legal principle that motive is not relevant in determining whether a unilateral contract has been accepted—knowledge and performance of the condition are sufficient.
This case has since played a crucial role in shaping the doctrine surrounding public offers and unilateral contracts, especially in circumstances where the offeror claims the claimant was not induced by the offer itself.
Factual Background of Williams v Carwardine
In March 1831, Walter Carwardine was murdered near a public house in Hereford. His body was later recovered from the River Wye in April. Following the murder, the deceased’s brother, Mr William Carwardine (the defendant), issued a public handbill dated 25 April 1831, promising a reward of £20 to:
“Whoever would give such information as would lead to the discovery of the murder of Walter Carwardine.”
At the time of the murder, Mrs Mary Anne Williams (the plaintiff) was married to Mr William Williams, one of the individuals later convicted for the crime. She had knowledge about the events surrounding the murder but initially withheld full details.
Between 13 and 19 April 1831, Mrs Williams provided limited testimony during the Hereford Assizes. The evidence she gave at that time did not disclose all that she knew. As a result, the two suspects were acquitted.
In August 1831, following a violent beating from her husband and believing herself to be close to death, Mrs Williams gave a second, voluntary statement. In this statement, she disclosed comprehensive and detailed information concerning the murder. Her own words declared that the reason for her disclosure was a desire to ease her conscience, given her poor health and “miserable and unhappy situation”.
This further evidence led to the conviction of three individuals in March 1832 at the Hereford Assizes: William Williams, Joseph Pugh, and John Matthews.
Mrs Williams subsequently claimed the £20 reward offered in the April 1831 handbill. However, Mr Carwardine refused to pay on the basis that Mrs Williams had not acted in response to the handbill, and her motive was entirely unrelated to the reward.
Plaintiff’s Statement
In her sworn deposition made on 23 August 1831, Mrs Williams described her observations on the night of the murder in March. She recounted seeing the deceased, Walter Carwardine, in the company of others, and she overheard critical exchanges that directly implicated the defendants. She described a voice pleading, “For God’s sake do not murder me”, followed by violent actions, a “dreadful blow”, and hearing the victim groan deeply twice, suggesting imminent death. She also identified the suspects and their movements post-assault. Her testimony ultimately contributed to their successful prosecution.
Legal Issue
The central legal issue in Williams v Carwardine was whether a person who performs the conditions of a public offer (in this case, providing information leading to a murder conviction), but is not motivated by the offer itself, can be said to have accepted the offer and formed a binding contract.
In simpler terms: Is knowledge of the offer and performance sufficient, or must the claimant act because of the offer?
Defence Argument
The defendant argued that Mrs Williams did not act in reliance on the handbill. The information she provided was not motivated by the promise of a reward, but by personal conscience and a belief that she was dying. As such, the defendant claimed, there was no contractual relationship between the parties, as there was no intention to accept the offer and no acceptance in the contractual sense.
It was also argued that the timing of the disclosure—months after the handbill was issued—meant the plaintiff’s actions could not be said to be in response to the offer.
Judgement at Nisi Prius
At the initial trial (nisi prius), the case was heard by Mr Justice James Parke. He took the view that motive was irrelevant, stating:
“The motive was the state of her own feelings. My opinion is, the motive is not material.”
He held that if the plaintiff knew of the offer and performed its terms, she was entitled to recover the reward, regardless of whether she was influenced by the offer.
Williams v Carwardine Judgement
The Court of King’s Bench upheld Justice Parke’s decision. The court, comprising Lord Denman CJ, Littledale J, and Patteson J, ruled unanimously in favour of Mrs Williams.
Several key observations were made during the appeal:
- Lord Denman CJ stated that the handbill was “a contract with any one who did the thing”, confirming that performance of the stated condition was sufficient.
- Justice Littledale explained that knowledge of the handbill and performance were enough, even if the person did not act because of the handbill. He said: “If the person knows of the handbill and does the thing, that is quite enough. It does not say, whoever will come forward in consequence of this handbill.”
- Justice Patteson concurred, asserting that: “The plaintiff being within the terms, her motive is not material.”
The court was satisfied that Mrs Williams knew of the reward (as it had been publicly posted in Hereford where she lived), and that she provided the crucial information which led to the convictions, thereby fulfilling the condition in the handbill.
The verdict was entered for the plaintiff with damages of £20.