Hodgson Brothers v South African Railways and Harbours 1928 CPD 257 was an important case in the South African law of contract, which represented one of the first clear deployments of reliance theory or the doctrine of quasi-mutual assent.
Hodgson Brothers, a small undertaking, informed South African Railways and Harbours that it had a lorry to sell for 500 pounds.
SA Railways made a complete and definite offer to buy the lorry.
Five days later, however, SA Railways sent a telegram notifying Hodgson Brothers that it had forgotten in their prior negotiations to mention that it would only pay 300 pounds for the lorry.
Although the court held that there was no subjective meeting of the minds between the two parties,—no animus contrahendi, in other words—it found that South African Railways and Harbours, by its conduct, had created in the mind of Hodgson Brothers a reasonable belief that there is consensus and therefore contract had occurred.