Lalman Shukla v. Gauri Dutt: Case Analysis


Allahabad High court


Justice Banerji


[1913] 40 ALJ 489


  1. Defendant (Gauri Dutta) Nephew had absconded and was nowhere to be found.
  2. Defendant become alert to the very fact sent all the servants to look for the missing nephew.
  3. Plaintiff (Lalman Shukla) was one among the servants of the defendant who went out in search of the nephew.
  4. Plaintiff eventually found the nephew and brought him back.
  5. Plaintiff got some money for railway fare and other expenses from the defendant to search out his nephew.
  6. As soon as the plaintiff had left the defendant’s house, the defendant announces a reward of ₹501 for those who find out his nephew.
  7. Though, the plaintiff has no idea of such an announcement.
  8. The plaintiff found the missing nephew and brought him back.
  9. Six months after from the said incident defendant terminated the plaintiff from his work.
  10. After being get terminated the plaintiff claimed the amount of money for the announcement which was made during the time of search of the defendant’s nephew.
  11. Defendant denied paying that claimed announcement remuneration.
  12. As a result, the plaintiff filed a suit against the defendant for not rewarding him as he was entitled to.


 The Issues raised in this case were as follows:

  1. Whether Plaintiff (Lalman Shukla) was entitled to induce the reward from the defendant (Gauri Dutt) for tracing the missing boy?
  2. Whether there was a legitimate acceptance of the offer made by the plaintiff?
  3. Whether there’s an existing contract or whether the situation amounts to any expressed contract between the two?


In this case, the plaintiff’s appeal against the remuneration of announcement reward of ₹ 501 by the defendant was dismissed by the court.

The court held that after analyzing all the fabric facts of this case that for creating or before entering into the valid contract there must have a piece of knowledge and assent to the offeree made by the offeror.

In this case, the plaintiff is unaware of the announced reward before the performance of his act. He come to know of the very fact after the performance of his act so there was no possibility of accepting the offer.

Therefore, there was no valid contract, and Plaintiff (Lalman Shukla) wasn’t entitled to claim the announcement reward.


This Subsequent case of Lalman Shukla (Plaintiff) & Gauri Dutt (Defendant) is that the case in which it was the first-time decided that “the validity of the contract in the absence of prior acceptance.”

According to this Landmark judgment, “a contract is said to be a contract when there’s knowledge of the offer made and that offer must be accepted”, in other words, a contract without acceptance is void-ab-initio.

Hence, despite his services, the plaintiff Lalman Shukla wasn’t entitled to induce the reward because the mere performance of the act does’t mean an assertion to the contract. Additionally, in virtue to turn an agreement into a proposal, it have to be enforceable by law. And at the tip, the communication of the proposals to an individual means that the person to whom the offer or the proposal is made must come to the knowledge of the acceptor before accepting the proposal.

Aishwarya Says:

I have always been against Glorifying Over Work and therefore, in the year 2021, I have decided to launch this campaign “Balancing Life”and talk about this wrong practice, that we have been following since last few years. I will be talking to and interviewing around 1 lakh people in the coming 2021 and publish their interview regarding their opinion on glamourising Over Work.


Do follow me on FacebookTwitter  Youtube and Instagram.

The copyright of this Article belongs exclusively to Ms. Aishwarya Sandeep. Reproduction of the same, without permission will amount to Copyright Infringement. Appropriate Legal Action under the Indian Laws will be taken.

If you would also like to contribute to my website, then do share your articles or poems at

In the year 2021, we wrote about 1000 Inspirational Women In India, in the year 2022, we would be featuring 5000 Start Up Stories

Leave a Reply

Fill in your details below or click an icon to log in: Logo

You are commenting using your account. Log Out /  Change )

Twitter picture

You are commenting using your Twitter account. Log Out /  Change )

Facebook photo

You are commenting using your Facebook account. Log Out /  Change )

Connecting to %s

This site uses Akismet to reduce spam. Learn how your comment data is processed.

Create a website or blog at

Up ↑

%d bloggers like this: