Williams v Carwardine

It also raises interesting questions about the necessity of reliance on an offer in the formation of a contract.

Walter Carwardine was murdered near a pub in Hereford in March 1831, and his body was found in the River Wye in April.

The plaintiff, Mrs Williams, gave evidence at the Hereford assizes against two suspects, but did not say all she knew between 13 and 19 April.

Mr Carwardine refused to pay, arguing that she was not induced by the reward to give the information.

“The voluntary statement of Mary Anne Williams, made this 23rd day of August, 1831, before me, one of his Majesty's justices of the peace in and for the said city, who, on her oath saith, that, in consequence of her miserable and unhappy situation, and believing that she has not long to live, she makes this voluntary statement to ease her conscience, and in hopes of forgiveness hereafter.

That, on Thursday night in the assize week, in the month of March last, between the hours of eleven and twelve o'clock, I went into Joseph Pugh's house, in Quaker's Lane, and there saw Susan Connop, Sarah Coley, Susan Reignart, Mr. Webb, the butcher, and Walter Carwardine.

I heard Pugh, Williams, Matthews, and Coley, about Mr. Thomas's house, the carpenter, three parts down the lane, towards the tan yard, I distinctly heard Pugh curse his eyes, and say, ‘Go on.’ Coley said, ‘Don't talk so loud; don't be in a hurry.’ I was very much frightened, and I got into the house, and went to bed.

The Court, consisting of Lord Denman CJ, Littledale J and Patteson J held, that the plaintiff was entitled to recover the £20.

The advertisement amounted to a general promise or contract to pay the offered reward to any person who performed the condition mentioned in it, namely, who gave the information.

— The plaintiff being within the terms, her motive is not material.This case has generated some controversy, because in R v Clarke the Australian High Court held that it was consistent with the proposition that "reliance" on an offer is essential for the possibility of acceptance, and therefore formation of a contract.

Lord Denman was Chief Justice for 18 years, from 1832 to 1850.