What did the court decide in this case?

The court said there was no valid contract because the government’s offer was meant for one specific person, and someone else pretended to be that person and accepted it.

Why does identity matter in contracts?

If the identity of the offeree is essential, accepting the offer under a false identity stops real consent. Without real consent, no valid agreement exists.

How is this case used in exams?

Students cite it to show that an offer for one person cannot be accepted by another. It supports arguments on mistake of identity and consensus ad idem.

Is the contract void or voidable here?

It is treated as void because consent is missing at the formation stage due to the identity mistake.

Which other cases connect to this principle?

Commonly paired with Cundy v. Lindsay and Boulton v. Jones, which also discuss identity-based mistakes in contract formation.

Law Easy

31 October, 2025

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Jaggan Nath v. Secretary of State for India (1886): Mistake of Identity & Contract Consent

Jaggan Nath v. Secretary of State for India (1886)

Mistake of Identity Contract Law Pun. Chief Court 1886 Citation: 21 Punjab Rec No. 21 India 4 min read

Author: Gulzar Hashmi India

PRIMARY_KEYWORDS: mistake of identity, consent, offer & acceptance
SECONDARY_KEYWORDS: consensus ad idem, misrepresentation, Indian Contract
PUBLISH_DATE: 2025-10-25

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Quick Summary

In this case, the government’s offer was intended for one named person. That person’s brother pretended to be him and accepted the offer. The court said: no true consent, so no valid contract. When identity is central, the wrong person cannot accept on the right person’s behalf.

Issues

Was there a valid contract between the plaintiff and the government agent?
Does a mistake about the offeree’s identity defeat consent at formation?

Rules

An offer meant for one specific person cannot be accepted by another.
Where identity is essential, a mistake of identity prevents consensus ad idem (meeting of minds).

Facts (Timeline)

Jump to Judgment

Timeline graphic for events in Jaggan Nath case

Offer: A government agent made an offer intended for the plaintiff.

Impersonation: The plaintiff’s brother posed as the plaintiff and accepted.

Dispute: On discovery, validity of the contract was challenged.

Arguments

Appellant

Acceptance occurred, so a contract exists.
Identity should not matter if terms are unchanged.

Respondent

The offer was personal to the named individual.
Impersonation blocked true consent, so no contract.

Judgment

HeldNo valid contract was formed. The court stressed that the government intended to deal with a particular person. The brother’s acceptance, done under a false identity, did not create agreement.

Ratio Decidendi

When the identity of the offeree is crucial to the offer, any acceptance by a different person is ineffective. Consent fails because the minds of the parties never met on the identity element.

Why It Matters

Protects personal choice in contracting partners.
Prevents fraud through impersonation in government and private contracts.
Guides drafting: name the intended offeree when identity is essential.

Key Takeaways

Offer to X ≠ offer to “any person.”
Identity mistake at formation → contract void.
Consensus ad idem includes identity, not just terms.

Mnemonic + 3-Step Hook

Mnemonic: “RIGHT PERSON, RIGHT PROMISE” → Wrong person? No promise.

Spot a named or specific offeree.
Check if acceptance came from that same person.
Conclude void if identity was faked.

IRAC Outline

Issue: Was a valid contract formed despite the identity mix-up?

Rule: An offer for one named person cannot be accepted by another; identity mistake prevents consent.

Application: The brother pretended to be the named offeree and purported to accept. The government intended to contract only with the named person. Minds never met on identity.

Conclusion: No contract; acceptance invalid due to mistaken identity.

Glossary

Consensus ad idem: Meeting of minds on the same thing in the same sense—includes identity.
Personal offer: An offer addressed to a specific person because their identity matters.
Impersonation: Pretending to be another person to obtain a contract or benefit.

FAQs

Identity can be part of the offer. If a different person accepts, there is no real consent and no contract.

No. Here the terms were fine, but the person accepting was not the intended offeree, so consent failed.

State the rule, give a one-line fact—brother posed as offeree—and conclude “no contract due to identity mistake.”

Cundy v. Lindsay and Boulton v. Jones—both stress identity when choosing a contracting partner.

Comment

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