Quenerduaine v Cole (1883) 32 WR 185
The plaintiff made an offer to the defendant by post, the defendant made a counter-offer by telegraph. The plaintiff accepted this by post, but by the time of receipt the defendant did not want to enter into the contract. It was held that the fact that the counter-offer was made by telegraph implied prompt acceptance was required, so by the time the letter had reached the defendant a counter-offer had lapsed and no contract was formed. Thus, where an offer was made by telegram there was an implied requirement that the acceptance should be made by an equally speedy method. Therefore a posted acceptance was not valid.
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