Can you claim a reward if you did not know about it?

No. Without knowledge of the offer, there is no acceptance. You cannot accept an offer you do not know exists.

Was there a contract between Lalman and Gauri?

No. The offer (reward notice) was not communicated to Lalman before he found the boy, so no contract arose.

Does a pre-existing duty affect reward claims?

Yes. Where the act is already owed to the promisor as part of duty, it does not count as consideration for a separate reward.

What is the key rule from this case?

Knowledge and assent to a proposal are essential. An offer turns into an agreement only when a person knows of it and accepts it.

lalman-shukla-v-gauri-dutt-1913

Lalman Shukla v Gauri Dutt (1913) 11 ALJ 489

Reward offers need knowledge of the offer — a simple, student-first explainer with timeline, IRAC, mnemonics, and FAQs.

Allahabad High Court 1913 Civil Appellate 11 ALJ 489 Contract (Offer & Acceptance) ~6 min read

Author: Gulzar Hashmi · India · Published: 26 Oct 2025

Quick Summary

Gauri Dutt’s nephew went missing. Her servant, Lalman, was sent to search. After he left, a reward was publicly announced. Lalman found the boy but did not know about the reward at that time. He later claimed it. The court held: no knowledge, no acceptance; hence no contract and no reward.

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Issues

Could Lalman claim the reward without knowing about it?
Was there any contract between Lalman and Gauri?

Rules

Knowledge + Assent

A proposal becomes an enforceable agreement only when the offeree knows it and assents to it.

Pre-existing Duty

Doing what one is already bound to do (servant’s duty) is not fresh consideration for a reward.

Facts (Timeline)

Timeline: search for missing boy and reward notice

Missing boy: Gauri sends Lalman to search and pays his travel expenses.

Reward announced: After Lalman leaves, a public reward of Rs. 501 is offered.

Boy found: Lalman, unaware of the reward, finds the boy near Rishikesh and returns him.

Claim: Later learning of the reward, Lalman claims it; Gauri refuses.

Suit & decision: Court holds there was no knowledge, no acceptance, and a pre-existing duty.

Arguments

Appellant (Lalman Shukla)

He performed the required act by finding the boy.
Therefore the reward should be payable.

Respondent (Gauri Dutt)

Lalman had no knowledge of the offer when acting.
His work flowed from a pre-existing duty as a servant.
Hence there was no contract and no consideration.

Judgment

Held: For Gauri Dutt. Since Lalman did not know of the reward when he found the boy, he could not accept the offer. Also, his act arose from a pre-existing duty. No enforceable contract existed.

Result: Reward not payable; suit dismissed.

Ratio Decidendi

An offer of reward can be accepted only by a person who knows of the offer and acts with that assent. Mere performance without knowledge does not form a contract; nor does doing what one is already bound to do.

Why It Matters

Clarifies reward and unilateral offers in Indian contract law.
Emphasises communication and intention in forming agreements.
Shows limits where pre-existing duty is involved.

Key Takeaways

No knowledge → no acceptance → no contract.
Reward claims fail if the act was a pre-existing duty.
Offers must be communicated before performance.

Mnemonic + 3-Step Hook

Mnemonic: “Know, Nod, Then Next.”

Know: Hear the offer.
Nod: Assent to it.
Next: Do the act → contract binds.

IRAC Outline

Issue

Can someone claim a reward without knowing of the offer? Was any contract formed?

Rule

Knowledge and assent to the proposal are essential; pre-existing duty is not fresh consideration.

Application

Lalman acted without knowledge of the reward and under duty to his master; no acceptance or consideration.

Conclusion

No contract; reward not payable; suit fails.

Glossary

Offer (Proposal): A statement showing intent to be bound if accepted.
Acceptance: Assent to the offer, made with knowledge of it.
Unilateral Contract: A promise in return for an act (e.g., reward cases).
Pre-existing Duty: A duty already owed; not fresh consideration for a new promise.

FAQs

Lalman did not know about the reward when acting, so there was no acceptance of the offer.

No. In unilateral offers, the act must be done with knowledge of the offer.

Lalman was already under a duty to search for the boy, so there was no fresh consideration for a reward.

Always ask: Did the claimant know the offer at the time of acting? If not, the reward claim fails.

Quick Nav

Case Meta

CASE_TITLE: Lalman Shukla v Gauri Dutt
PRIMARY_KEYWORDS: knowledge of offer, acceptance, reward, unilateral contract
SECONDARY_KEYWORDS: communication of offer, pre-existing duty, Indian contract
PUBLISH_DATE: 26-10-2025
AUTHOR_NAME: Gulzar Hashmi
LOCATION: India
Slug: lalman-shukla-v-gauri-dutt-1913

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