Case Brief |Williams v Carwardine (1833)

IN THE COURT OF KINGS BENCH

CITATION: 4 Barnewall and Adolphus 621; 2 LJKB 101; 110 ER 590

BENCH: Lord Denman CJ, Littledale J, Patteson J, Parke J

INTRODUCTION

The Law of Contracts is considered one of the most complex and significant developments that take place in Students studying Law. The case of William vs Carwardine (1833) is a landmark English Case Law that briefs us with the key concept of the Law of Contracts where a contract comes into force through the offer of a reward.

FACTS OF THE CASE

In this case, a woman Mrs Mary Ane Williams who is the spouse of Mr Williams Williams claimed a reward of 20 pounds from Mr Carwardine for giving information that led to the arrest of her husband. 

In this case, Mr Carwardine’s brother was murdered by Mrs Williams husband.

Walter Carwardine brother of Mr. Carwardine was murdered near a pub in Hereford in March 1831 and his body was found in river Wye in April.

Mrs Williams gave evidence at Hereford against two Suspects but did not say everything she knew between 13 and 19 April the suspects were acquitted.

Later the victim’s brother put up a price reward of 20 pounds if anyone comes forward and gives any information related to the case. 

Mrs Williams was often bruised and beaten by her husband thinking that she might die soon in order to ease her conscience and feel free of the burden of covering up for the crime her husband committed stepped forward and gave her statement that made the conviction of the offenders happen.

Later on, Mr Carwardine who put up the price reward of the informer refused to pay Mrs Williams 20 pounds saying that she stepped up to give the information just because of the reward money. At the trial, her motives were examined and the court decided that Mrs William’s confession was free of any greed related to the reward money.

Issues Framed/ Raised

• Has the plaintiff formed a contract with the defendant in spite of the fact she was not motivated by the reward money when the information was given?

FINAL JUDGEMENT

After hearing both side’s arguments and considering the facts that the bench was served with the panel of judges came to the decision that favoured the claimant and she was allowed to recover the award. 

The Court held that if an offer has been accepted with knowledge of the reward that is offered therein, the mere fact that the informer was influenced by motives other than claiming the reward shall be immaterial.

DOCTRINES ESTABLISHED

The court gave a landmark judgement when they put together the concepts of the Contract Law and came up with the establishment of the fact that the influence of other motives while having the knowledge of the reward does not affect the contract and the contract is very much valid in front of the law.

CONCLUSION

The law of contracts consists of facts and theories that can make a small judgement complex and also next too impossible to judge a case.

But, the case of William vs Carwardine shows us that if we stick to the basic concepts and theories that are established in the Law of Contract the interpretation of the case can be made easier and the process can be made smoother.

• BY: ASHISH NAVAL SHUKLA
• BENNETT UNIVERSITY; 2^ND YEAR BBA LLB