Gibbons v Proctor (1891) 64 LT 594
Facts
A reward was offered for information leading to the conviction of an offender. Gibbons supplied information through an intermediary while initially unaware of the reward. Before the information reached the person designated by the offer, he learned that the reward had been advertised. He subsequently claimed payment. The dispute therefore concerned the relationship between knowledge and the completion of the requested information-giving process. It is reported briefly, making it important to distinguish the initial communication to the intermediary from the later delivery specified by the reward arrangement.
Legal Issue
Was the claimant entitled to the reward where he learned of the offer after giving information to an intermediary but before its required delivery?
Held
The claimant recovered the advertised reward. The important timing point was that, although he initially passed information to an intermediary without knowing of the offer, he learned of it before the information reached the person designated to receive it. The stipulated performance could therefore be analysed as completed with knowledge of the offer.
The brief historical report should not be treated as a strong authority for accepting an offer in complete ignorance of it. Nor does the outcome establish a general doctrine of retrospective acceptance after performance is over. The destination and communication requirements in the reward offer matter to identifying when performance was completed. The case is best used cautiously for that factual timing issue, with the broader knowledge requirement analysed separately.
⭐ Legal Principle
In a reward case, identify when the stipulated information or performance actually reaches the required recipient. Gibbons is weak authority for acceptance without knowledge, because the claimant learned of the offer before the relevant delivery was complete. It should not support a general rule of retrospective acceptance.
Significance
Gibbons is valuable chiefly as a warning against simplifying a short historical report into a broad rule. Reward problems require attention to the offer's specified recipient and the timing of knowledge, not just the moment information first leaves the claimant. The case should be taught alongside the general requirement of acting with knowledge of the offer. Where the facts do not resolve that timing, a confident conclusion that an unknown offer has been accepted risks teaching a disputed proposition as settled law.
Common exam questions about this case
When did Gibbons learn of the reward?
The supplied account places his knowledge after giving the information to an intermediary but before its arrival with the designated recipient. That sequence matters because the required performance could still be incomplete when he learned of the offer. The case should therefore not be described as straightforward acceptance in total ignorance.
Does Gibbons establish retrospective acceptance of any completed act?
No. Its limited facts do not support such a general rule. The argument for recovery depends on when the specified performance was complete and whether knowledge existed at that stage. An act fully completed before learning of an offer raises a different question which this report should not be used to resolve automatically.
What should a reward-problem answer identify first?
Read the offer to identify exactly what information or result is requested and to whom it must be delivered. Then place knowledge and performance on a timeline. Gibbons shows why a preliminary communication to an intermediary may not be the same event as completion of the offered condition.