What rule did Entores establish?

For instantaneous communications like telex, acceptance is effective when received by the offeror, not when sent.

Does the postal rule apply to telex or email?

No. The postal rule applies to non-instant methods like post. Instant methods work on receipt.

Where was the Entores contract made?

In London, where the acceptance was received. So English law applied.

Why does the place of receipt matter?

It decides which court has jurisdiction and which law governs the contract.

What if the message fails to reach due to silence or noise?

If the offeror does not receive or cannot hear the acceptance and knows that, there is no contract until communication is clear.

entores-v-miles-far-east-corporation-communication-of-acceptance

Entores v. Miles Far East Corporation (Communication of Acceptance)

Contract Law Court of Appeal (EW) 1955 Citation: [1955] 2 QB Bench: Denning LJ Reading time: ~4 min

Author: Gulzar Hashmi | India | Published on 26 Oct 2025

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Quick Summary

Entores in London sent an offer by telex to a company in Amsterdam. The Dutch company sent back a telex accepting the offer. The deal later failed. The court said: for instant messages like telex, acceptance works when received, not when sent. So the contract formed in London, and English law applied.

Issues

Was acceptance complete in London or Amsterdam?
Which law should govern—English law or Dutch law?

Rules

Acceptance must be communicated before a contract is enforceable.
For instantaneous communications (telex/phone), acceptance is effective on receipt, not dispatch.
The postal rule does not apply to instant methods.

Exam Tip: Place of receipt = place where contract is made → governs jurisdiction/law.

Facts (Timeline)

Timeline visual for Entores v Miles facts

Offer: Entores (London) offered to buy 100 tons of copper cathodes by telex.

Acceptance: Miles Far East (Amsterdam) sent a telex accepting.

Breach: The defendants did not complete the contract.

Claim: Entores sued for damages in England.

Arguments

Appellant (Entores)

Acceptance was received in London → contract in London → English law applies.
Postal rule is not for telex; it is for post.

Respondent (Miles Far East)

Acceptance was sent from Amsterdam → contract there → Dutch law should apply.
Try to extend postal rule to telex dispatch.

Judgment (Held)

The Court of Appeal held that the postal rule does not apply to telex. Acceptance is effective when received by the offeror. So the contract was made in London, and English law applied.

Instant methods (telex/telephone) → acceptance on receipt.
Place of contract = place of receipt.

Ratio Decidendi

Communication must reach the offeror for acceptance to be complete in instantaneous communications. Dispatch is not enough.

Why It Matters

Guides email, fax, chats, and other instant methods.
Fixes jurisdiction when parties are in different countries.
Keeps contract law consistent with real-time messaging.

Key Takeaways

Postal rule ≠ instant communications.
Acceptance effective on receipt.
Place of receipt decides governing law and court.

Mnemonic + 3-Step Hook

Mnemonic: “RING = Received Is New Ground”

Received message seals the deal.
Is where the contract forms.
New Ground: postal rule set aside for instant tech.

3-Step Exam Hook

Identify the medium: post vs instant?
If instant → acceptance on receipt.
Locate receipt → choose law/jurisdiction.

IRAC Outline

Issue

Was the acceptance complete in London or Amsterdam, and which law applies?

Rule

For instantaneous communications, acceptance is complete on receipt. Postal rule does not apply.

Application

The telex accepting Entores’ offer was received in London. Thus, communication was complete there.

Conclusion

Contract formed in London; English law applied.

Glossary

Instantaneous Communication: Real-time methods like telex/telephone/chat. Acceptance is effective on receipt.
Postal Rule: Dispatch rule for post: acceptance complete when letter is posted—not used for instant methods.
Jurisdiction: Legal power of a court; here linked to where acceptance is received.