Byrne & Co v Leon Van Tien Hoven & Co [1880] 5 CPD 344 is a leading English contract law case on the issue of revocation in relation to the postal rule.
In it Lindley J of the High Court's Common Pleas Division ruled that an offer is only revoked by direct communication with the offeree, and that the postal rule does not apply in revocation; while simply posting a letter counts as a valid acceptance, it does not count as valid revocation.
[1] Van Tienhoven & Co posted a letter from their office in Cardiff to Byrne & Co in New York City, offering 1000 boxes of tinplates for sale on 1 October.
When, however, those authorities are looked at, it will be seen that they are based upon the principle that the writer of the offer has expressly or impliedly assented to treat an answer to him by a letter duly posted as a sufficient acceptance and notification to himself, or, in other words, he has made the post office his agent to receive the acceptance and notification of it.
[4]Lindley's judgment notes in part that the postal rule cases which he reviewed include an express or implied consent by an offeror to treat an answer duly sent by post as an acceptance.