Dodgson Hamilton Madden

He was also a leading barrister, who held office as Serjeant-at-law, Attorney General for Ireland and subsequently as a judge of the Irish High Court.

Though not much interested in politics, he was diligent in performing his duties, and worked well with Arthur Balfour, the Chief Secretary for Ireland, particularly on the issue of land purchase.

Admittedly his reputation was bound to suffer in comparison to such outstanding contemporaries as Christopher Palles and Hugh Holmes, in an era when the quality of Irish judges was as high as it has ever been.

This verdict was probably too severe; in particular, Madden's judgment in Boyers v Duke remains a valuable decision on the formation of business contracts.

Madden, drawing on his knowledge of English literature, cited Jane Austen and Sir Walter Scott, among other authors, to prove that "humph" had a definite meaning, namely an expression of disagreement.

His judgment in Boyers v Duke[3] is a leading decision on the concept of offer and acceptance in contract law, and in particular, the precise meaning of a quotation by a seller of goods.

Applying normal rules of commercial practice, he found that if every quotation was in itself an offer which could lead to a binding contract, the business in question would be so swamped with obligations which it could not meet that it might well go bankrupt.