Report on Postal Rule in the UK

Table of Contents

Introduction 3

The Postal Rule – An Assessment 5

The Postal Rule and Modern Technology 6

Main Elements of a Contract 7

Offer 8

Acceptance 9

Intention to Create Legal Relations 10

Consideration 10

Consideration must move from the promise; 11

Past Consideration 12

Consideration must be legal. 12

Consideration must be sufficient but does is not required to be adequate. 12

Postal Acceptance Rule in the Digital Age 13

Justifications of the Postal Acceptance Rule 13

Postal Acceptance Rule and Email Acceptances 15

How is E-mail Transmitted? 15

Postal rule: history and development 16

Postal Rule: Revocation 17

Justifications for the Postal Rule 17

The exception to the postal rule: The Telex 18

Conclusion 22

Introduction of Postal Rule in the UK

The postal rule is a benchmarking and historical ruling, and it has been attained within the time period when the main and rapid form of business communication was being done with the help of the post. As the centuries have gone by, the various forms of communication were developed, which have been a lot quicker such as telex, phone, and in recent times, the fastest messages, as well as, the email. The central requisites for the formation of contact are those, which have been offered and accepted. Despite all of this, the overall rule in law described that acceptance has been communicated, and it has been received by providers. Moreover, the ruling is implemented along with the means of communication, which has been considered as instantaneous Entores Ltd v Miles Far East Corpn (1955). One of the exceptions to the rule on the receipt and communication; which has been obtained from the postal rule. It is important to know that the postal rule has been implemented on the non-instant modes of communication. It is involved in the post and telegram (Cowan v O’Connor (1888). The actual rule is that the acceptance is taken place, when the givers send their acceptance, not when they received it by the offeror. The rule is an expectation to the contract within the communication because it has been taken as a meaning in which acceptance has been made without being communicated to the provider. This rule was developed in Adams v Lindsell (1818) (Lawwithdenise, 2018) . 

The overall rule for communicating acceptance by post had been outlined back in the Georgian case and in other few cases, where the vacant accepted by post, and this has been obtained as having taken all the duties steps upon the posting of the letter, and then placed them in the letterbox  (LAWTON, 1974) . It happens for the two reasons; first, by doing so the vacant has been done all that the possibility and letters, are now in the hands of postal services; and number two if the vacant has any issue or concern, which is related to acceptance of being communicated by post. This is how they can specify as between the primary offer.

The latter reason establishes one of the major exceptions as to when the postal rule cannot be implemented. Some of other involved expectations are given below:

• When the consequences are of such kind, which have been utilized the services of postal to communicate the acceptance, and which have been exterior to the observation of parties. This would be implemented when the distance among two parties might reduce the usage of post unrealistic, as well as, where the distant location, one of the party might leave it implausible that the post will attain or where the subject matter of the receipt would be taken as too private and personal to threat the post being interrupted.

• Where the vacant specified that the acceptance should be communicated by the specific time, the courts might not accept the postal rule if by utilizing the postal services, the offeree has efficiently made sure that the acceptance will not reach the vacant within time. 

The Postal Rule – An Assessment of Postal Rule in the UK

The continued presence of the postal rule has faced the vexed issue, as well as, the assessment essays outlining their relative merits and flaws, which were mainly expected from law students, who have come in the season of the exam. It comes with the stance of a complex test, mainly when judiciary and academic likewise decided what to create of it. 

There are some of the advantages, which have been mentioned here: the rule condenses fraudulent claims for the party about the entrance of a letter of acceptance, which is impossible. The offeror did not lie about not receiving because it is not related to the content, and the receiver can often lie about did never posting because the letters mainly reached their destination. Moreover,  Thesiger LJ has explained in the domestic fire and some of the carriage Accidents Insurance Co Ltd v Grant (1878) LR 4 Ex D 216, how it is required, and in this regard vacant will always inspect some of the vacant, whether or they might not be communicated their acceptance. Moreover, it is depended on the strength of this rule, and in this the offeree which could start to perform his responsibilities recently after posting his acceptance which was taken as in the meaning in which mainly facilitates the rapid up of commerce (LAWTON, 1974)  Moreover, this will overlook the fact which offers or did not start performing their duty and the line of reasoning taking account indecision which has been presented behind Lord Wilberforce’s initial statement in Brinkibon and this will not be implemented on the rule of postal until the letter mainly reaches offertory’s doorstep. In the condition of responsibilities, the performance which is time-sensitive and some of the postal rule has been weighted within the in favor of the offered without any justification as to why. Certainly, the judgment, which has been made, revealed an open displacement for the postal rule along with Russell.   

In short, some of the postal rules have for the most significant part of which has been starting getting their job which is being continued since 1818. The courts and lawyers, all were the same with the defective used and to pledge a modification, which will be to embroil English contract law in the difficult debate unlikely to generate any meaningful outcomes.

The Postal Rule and Modern Technology of Postal Rule in the UK

It has been border-line as to whether the postal rule must be implemented on the latest technology. It has been explained through an example, in this, it is mentioned that the Marwan Al Ibrahim et al make the arguments, which would be implemented to email and probably texts with the exact logic on the basis that email is not the sudden method of communication, despite form this the digital version of the routine post. Moreover, the referencing pronouncement of Rajah JC in the Singapore case of Chwee Kin Keong v Digilandmall.com Pte Ltd [2005] 1 SLR(R) 502, they criticized as the emails have been processed along with the servers, routers and some of the internet service providers, as well as, email has been placed in the hands of the third party while sending mails. 

Furthermore, it has been followed in the form of normal postal, and an email acceptance must be taken in the form of having been sent at the time of acceptance, which has been going out from the ownership of the offeree and within the ownership of the third party which sanction to receive it. The third-party obviously in the condition of email, which is the ISP and for communication of the network carrier. 

But this criticism did not follow. The justification behind the postal rule is not that something has been taken into within the hands of the third party, and the offeree takes all the significant steps that he can bring to this acceptance or the attention of the vacant. Despite this, the major preseason of the presence of postal rule is the following of postage and there is no process for considering when the letter has been failed to send. This was not in the case of email for which an immediate error message has been observed and would be sending after the failure of delivery (Reeves, 2016) .

The better opinion is that which had been implemented in the English courts in the case of Entores Ltd v Miles Far East Corporation [1955]: that the postal rule did not put on. As had been long-established in Brinkibon by Lord Wilberforce:

Postal Law Adjustment of Postal Rule in the UK

The person who has considered the agreement on offer can appear to impose the indenture. A third party did not administer the agreement, although they have an attention in the contract, as the contract which has been made between the aptitude and promisor Twiddle v Atkinson (1861;) McCoubray v Thomson (1868). This approach of consideration had broadly hated as in most of the cases and third parties hold the specific interests in agreement yet they will not legally contest this perspective of consideration as it had been observed privacy of indenture. There had called for an adjustment to this rule and in 1999 the Agreements (Rights of Third parties) Act had been bringing within the legislation. In effect provided the right to third parties to implement agreements where there was a benefit, despite the deficiency of consideration.

A postal rule must be legal of Postal Rule in the UK

If an act had been illegal and an individual was completely acknowledged for this and costs did not be recovered. Pearce v Brooks (1866)

Passable consideration linked to the estimated value of the consideration; the legislation would not be evaluated because someone transferred a bad deal. Modicum associated with whether the consideration has been documented by commandment as good and with value. Under this rule, if two parties transfer a contract and have in contract to the value, but others might believe the estimate not passable, due deliberation which had been given and can be demonstrated to be appropriate.

Key case law had been the case of Chappel & Co v Nestle & Co (1960). Nestle contended an elevation. To get the greatest domestic and had to succumb three covers of a Nestle bar and an amount of money. Sovereigns have been paid out on the normal trade price of the record. The complainant claimed that the price of the bars must be standard as consideration. The court detained for the litigant, where they estimated the covers had been the part of the thought, individuals would have to buy three bars at financial value, however when they had no value to Nestle. Nestle deserted them on return ( Mulcahy et al , 2004) .

Main Elements of a Contract of Postal Rule in the UK

A contract has been taken as the legally binding agreement which has been done among two or more than two parties. It is also classed as one of the most significant legal mechanisms within the business. While signing the contract some of the major components which contribute to the document started legally binding as given below:

1. Acceptance 

2. Offer 

3. Consideration

4. Intention to develop legal decisions 

Courts would found that some of the contracts are not valid even if any of the significant criteria which explain that the contract was missing. The contact can be supposed as:

• Void: the contract was not affected legally

• Voidable: the contract is legal until such time it is developed void by the need of the party 

• Unenforceable: did not be enforced by the courts due to the deficiency of legal evidence and the contract was agreed. 

In this regard, the contract has been made through various forms of communication. Written, oral, or disguised by conduct  (Farry , 2002) .

Offer of Postal Rule in the UK

It is mainly accepted that a vacant begins the procedure of contract which has come into being. An offer has been taken as the expression of inclination to start the business as one of the specific terms and situations. Offers might be communicated to persons required to get aware of the presence of an offer to give acceptance. Offers could be appropriate or overall which can be accepted by the individuals and it had been addressed in the case of Boulton v Jones (1857). An overall offer has been made from the community at huge and anyone, who realizes that they can complete the terms of the offer could submit an acceptance. Carlill v The Carbolic Smokeball Company (1893).

Acceptance of Postal Rule in the UK

If an offer has been accepted, the offered unintentionally agrees with the terms of vacant, and the basics of the contract which has been started withdrawn up. The acceptance has been communicated to the vacant. There are various forms of communicating acceptances in the recent business atmosphere along with instant communication methods which will be such as phone, fax, email, and some of the telegrams and posts have been utilized. The vacant or instruct within the terms of method and the acceptance must be communicated and has been identified the time limit for the acceptance which has been received. The receipt can be considered unacceptable if interconnected in a dissimilar way than required (Griffiths et al , 2002) .

Intention to Create Legal Relations

It has been supposed many of the profitable agreements have been envisioned to be lawfully obligatory. If a party would not be satisfied in a contract and attempts to get the contract canceled, the responsibility would be on them to demonstrate the contract has no legal stand-up. Some do arrive sections to the consequence that the contract will not be binding in a court of law; illustration, where you discover this today will be rivalries in newspapers, with the enclosure of the section “editors’ decision, is final”. Key case involving to the problem of developing legal purposes is Rose & Frank Co v JR Crompton & Bros (1925 where an honor article had been written into a contract. When an argument ascended, the courts mentioned that the perpetrators Rose was to honor the unsettled instructions which had been placed on them by the plaintiff's JR Crompton, as they were accepted but do not have to endure with the arrangement or receive any recent orders.

Consideration of Postal Rule in the UK

It can be determined as the price or value parties approve on for a potential on offer. If it has been proved that there is no deliberation, rather than it has been believed that no agreement has been present. Consideration should exist for a contract to be valid. Consideration must be either executed or executory. Executed narrates to the resonant out of a potential or reimbursement for that potential in the current time. Executory has been associated with the carrying out of the promise or creation payment for the potential in the upcoming. Consideration should be move from the potential for the legislation to suppose that the consideration was taken place. It should also be occupied that the reflection is believed adequate that it is good and has a value. Under consideration, the courts did not contemplate the value. If a party negotiates a bad deal, consideration does not have to be adequate. The court's role is to make sure that consideration had enough. 

Consideration can be classified into two ways:

• Executed- it has been associated with the payment for the promise in recent times.

o E.G purchasing groceries in the shop and directly paying for them.

• Executory-connected to the payment for the promise in forthcoming.

o Hiring utensils, payment has occurred once in the future, and the tool has been delivered for usage.

While discussing consideration there are main rules which is associated with the subject.

Postal Rule in the Digital Age

This article is for the evaluation of the uses of postal acceptance rule into the email acceptances. Against the use of conventional rules, for example, the rules for acceptance of postal that came into being in 1818, various views were on the debate as something that was on legal contract into the modern form of communication such as email. This paper is a clear demonstration of those debates and all rationales that were established on the back of the application of postal acceptance rules and merge its use with modern communication through emailing etc. This research concludes that email can never be a quick method for communication but can only be seen as the digital face of normal posts and thus we can say that it is easy to apply postal acceptance to such kind of contract.

Justifications of the Postal Rule

The very first establishment of the postal rule was in the case of a court of Adams (Lindsell). That was the time when the court needs to put an agreement on the time of contract formation for the post. The court noticed that people in parties when communicating post-acceptance, they were quite not sure at that moment that the communication is the post-acceptance. The postal communication is thought to be delayed subject because members were not aware at the moment about the communication of postal acceptance. This created many issues and ultimately result in the establishment of the rules. The rule that was established, and it acted through the legal systems, and the rule was “the communication under the contemplation of the parties, under the usual usage of the people, the use of the post could also be as the mean of communicating about the postal acceptance offer, the acceptance will occur at the time it will be posted”. Under the circumstances of face to face communication, the uncertainty that happened at the time of formation of the contract would not happen and even at the contracting through the distance where an instantaneous strategy for the communication could be applied. All the members of the parties are quite well aware of the conclusion in these types of contracts and they do not have to deal with issues like late or even failure for the transmission which usually is the property of non-instantaneous communication (Yamaguchi, 2004) . 

For the longer validity of the rule, there is another suggestion or the reason is that the offer should be considered as the genuine offer made through all this time that the offer is staying in the post. So, in this way agreement between members will be complete when the acceptance will get posted too. This offer will produce a power that unites both members of the parties and the acceptance could be considered as the practice for that power and all this idea is depended on this perception. But it is also true that after the formation of the offeror that determination, the results that will occur legally will get out of control because the offer will have its effective importance and then it is also possible that the offer will have the privilege over the process of the contract formation. It is also quite possible that the offer will require an additional period to decide that should they accept or reject the offer and they could also use their money as well as their efforts to approach particular decisions during that period. 

Postal Rule and Email 

Some researchers and authors have described their views as the email and other ways of contracting through the internet are the communications that are termed as instantaneous communications and there is the general rule for the acceptance that can also be applied to this situation of acceptance (Hill,204). While talking about the website acceptance, this can be true in the argument because there is no clear space in the period between accepting and after sending that offer. The email messaging transfer, in this case, is different from the contracting on the web as we can see and determine in the following points.

How is E-mail Transmitted? 

The one who is going to send some email message through the account can draft a message that it alters on going to send in case if he or she do not have any connection of internet at that moment. When the user produces the message on the computer, the initials step for the journey of sending email start when the computer gets to connect to an internet service provider (ISP). The second step happens at the moment when the person presses the icon or bottom of ‘send’ which in the case when network is not congested with heavy work and the address of the email of the receiver is typed correctly on the box of the recipient, the message is transferred to the international network of computers before it is received by the other user whose email address has been entered. With the help of an internet service provider or ISP, the email bounces from a minimum of the computers of many and millions of them until it completes its journey at the ISP of the receiver. After this, the receiver will be able to retrieve that message by correctly logging in to their server of internet ISP and thus can download the message ( Ibrahim, 2007) .

Postal rule: history and development

In the 19th century, the postal rule was established almost to address problems that also include the production of the contract through the post. This rule makes an exception for the general need for the acceptance communication, was them to evade an extraordinary result that can survive the offer by revoking at any moment before the acceptance of the letter before its  be received. We can also say that the offer, who has initially posted the letter for the acceptance will always not be sure about the acceptance of the letter. So, once the letter of acceptance is launched or transmitted, it is not possible to cancel that offer after its transmission. In another case, it could cause many issues that can also get difficult to resolve at the moment. Adam v Lindsell was the landmark case for this rule, where the court decided that post-acceptance is effective after the post of the acceptance and it will no longer get retrieve by the offer. The time when the offer approach and read the post-acceptance it will all be irrelevant and useless. Uther fact is if the letter is unable to approach the offer safely or occur to get lost in transit is also irrelevant and immaterial (Che , 2019) . 

Postal Rule: Revocation of Postal Rule in the UK

The postal rule is under pressure in some areas where the actual offer gets revocable or when into comes into effect? If talking about the linkage with the commencement of things it does that are needed under unilateral offer the time in this case for revocation is quite important. The offer revocation is quite a complex subject if talking about the postal rule. But still, there is a dichotomy that is preset between times of consideration, the letter is similar in posting but not when they reach in the knowledge sphere of that particular offer. On the other hand, the letter of revocation only comes into action when there is a proper delivery for the letter revoking the offer. The offer must get the letter of revocation to be an effective revocation. As a result, we can say that delay or even now receiving through the post is not important in the context of acceptance communication, as compared to their role in revocation. “Irrevocable offer was legal impossibility” is a legal doctrine and to fit in it, the revocation can happen at any time. But the actual issue here is that this doctrine is opposite to postal rule because this doctrine constantly needs the offer to bind instantaneously. But the concept here is that any offer can be revocable until the time of requested full consideration approach. 

Justifications for the Postal Rule of Postal Rule in the UK

There are numerous suggestions for the justification of the postal rule in previous years to explain and examine the utility of the rue and all its rationale. But many of these justifications are dismissed on the floor long ago. The initial justification depends on the conventional idea for the mind meetings or it can also call as consensus ad Adam because this conventional view came from the case of Adams v Lindsell. In this regard, we can say that at the time of census ad Adams or mind meeting approach and then there is a time to legally bind as soon as the letter gets dispatched because otherwise, the conventional rules cannot apply to it. But if this case will not occur and the rule for the dispatch was never came into being, then there will be the foundation of legal fiction for the contract acceptance by the post because the time related to acceptance offer will get delays as linked to real point time. But we can also say the knowledge about the offer is as much important as the offer intent because there is quite a possibility that the offer will change the mind before a letter will get approach and hence, cannot happen to have a census. All the advantages of the Adams rule will vanish away when the offer will get withdraw or the seat is taken by the faster mean of communication, which can approach the offer before the acceptance can as in the case of the US.

The exception to the postal rule: The Telex

There are many other ways of communication in use from decades like speedier. Telex was also one of those. With the introduction of telex, as compared to the telegram, the postal rule started to give its first flaw. There were 2 cases about whether the dispatch rule should apply to the modern communication form or not. There were several tests about instantaneous from telex of Entores Ltd v Miles Far East Corn it was concluded that telex was a virtually instantaneous way of communication. So, when acceptance tends to send through the telex “it is not before the receival of the message at the coalition of the contract. It was concluded by the court that the contract is produced after the receivable of the acceptance through the plaintiffs so it was thought that dispatch, as well as the receipt of the messages, are not instantaneous completely, just like the telephone communication, members are all intents in each other existence and I can see no valid reason for the departure of the usual rules that there will be no existence of binding contract before the notice for offer acceptance is received” (Defossez, 2019) .

Given Draft of Postal Rule in the UK

The postal rule is a benchmark ruling in the context of contract law. This rule was established in a time where the post was the fastest and most efficient mode of communication. The four elements of a valid legal contract are an offer, acceptance, consideration, and the intention to create legal relations. The postal rule is an exception to the general rule of acceptance. An acceptance in the context of contract law is defined as an unequivocal assent by the offeree to the terms proposed by the offeror. The general rule of acceptance is that it must be communicated to the offeror for the acceptance to be valid.  This was established in the leading case of Entores v Miles Far East Corp.  When post is used to communicate between two parties there is a slight change to the general rule of acceptance. In the historic Case of Adams v Lindsell , it was held that where acceptance is communicated by post, the contract is formed as soon as the letter of acceptance is sent without the need for it to reach the offeror. The postal rule applies even if letter of acceptance never arrives and the offeror is ignorant of the fact that an acceptance was posted by the offeree . A similar approach was taken by the courts when deciding the case of Household Fire and Carriage Accident Insurance Co. Ltd v Grant .  Hence, it is clearly visible that the postal rule of acceptance is a rule which seems at first sight, quite unreasonable and hard to justify, as it goes against the normal order of day to day human interaction. There are certain reasons why I truly feel that maybe change to ‘consider’ or ‘seek to argue that the postal rule is in need of being replaced. Firstly, the postal rule places the risk of loss and delay on the offeror. This is because the offeror will be blindly bound by a valid legal contract despite him or her not receiving the letter of acceptance by post.  If by any chance the letter of acceptance is lost in post the offeror may believer that the offeree is not interested in the offer as the offeror has not received the particular letter. Hence, the offeror has the right to believe or may think that there will be no question of breach if a contract relation to the same subject matter is made with another party. However, there is a solution to the problem above. An offeror can state in his offer that an acceptance to the offer that he or she has put out will only bind if the letter of acceptance reaches him.  This approach, which renders the postal rule modified, put forward by Bramwell LJ in His Lordships powerful dissent in the case of Household Fire and Carriage Accident Insurance Co. Ltd v Grant . Lawton LJ opined similarly, when stating that the postal rule does not operate if its application would manifest inconvenience and absurdity. His Lordship was of the opinion of that an adoption of such a principle requires departure from a binding precedent then the principle should be rejected. One will definitely wonder why the English law adopted the postal rule in the first place if the application of the rule is bound to bring plenty of complications. But exceptions can prove the need for a rule, and one of the many suggested reasons is that if the postal rule did not exist, no contract would ever be so readily completed by post. This is because, if the offeror is only bound when he or she receives the letter of acceptance from the offeree, then the offeree should only be bound when the offeree himself has received notification that the offeror has received his acceptance letter and has assented to it .  This may go on ad infinitum.  A simple solution to this would be to put a rule in place that would only give rise to acceptance only when the letter from the offeree is received by the offeror regardless of whether the offeree is aware of this. This rule if it was adopted by English law would definitely defeat the infinity of letters scenario. Furthermore, another suggestion is that the postal rule reduces the difficulties of proof. It is mentioned that it is easier to proof that a letter is posted than to prove that the letter is received . Nevertheless, this definitely depends on the efficiency of the parties on keeping account of the posting of the particular acceptance letter. One cannot deny that the postal rule is in favor of the offeree and it is mentioned that the offeror accepts the risk of delay and accidents in post. On the other hand, the offeror can protect him from the risks by stipulating that he or she is not bound until the letter of acceptance is received. Neither of these suggestions is entirely satisfactory. However the strongest justification for the adoption of the postal rule is that it curtails the power of the offeror to withdraw his offer. This was adapted in the case of Byrne & Co v Van Tienhoven & Co . This is not satisfactory either as it does not clearly justify or clarify the reason behind the adaptation of the postal rule. It would suffice if the law concludes that once the offeree has posted the letter of acceptance the offeror would not be able to revoke his offer. 

 In general –

This is potentially a good, interesting discussion that’s clearly going in the right direction. Although I’ve marked up some points these are all to do with tidying up points, sharpening expression etc., and don’t in any way take away from merits of what you are doing. Above all your writing has the great advantage that it makes your subject accessible – and that means the reader actually wants to go on reading.

Do make sure you lead up to a good strong conclusion.

Conclusion of Postal Rule in the UK

In this, it has been concluded that the rule of postal has been taken as historical ruling, and it has been attained within the time where the main and rapid form of business communication had been done by post. Along with these centuries, various forms of communication have been developed which has been now quicker, telex, phone, and in recent days fastest messages and also the email. Despite this, the major preseason of the presence of postal rule is the following of postage and there is no process for considering when the letter has been failed to send. This was not in the case of email for which immediate error message has been observed and would be sending after the failure of delivery. 

The issue addressed by the present study is the application of the postal acceptance rule in place of email acceptance. It looks as if the application of the postal rule is justified and it is also valid to be applied in the age of a post, which can be analogized with a new communication system, like email. Email is a good way of communication, but when it comes to making instant communication, it cannot be considered instantaneous because it comes with various gaps and delays between the process of sending & receiving. The two parties communicating through emails cannot communicate on an instant basis while using the method of email. That’s why our argument comes with persuasive reasoning that any legislative action is considered absent at the time of contract conclusion, which is done through email. Having contrast to that, the clarity is greater when a general rule is applied to the website acceptances. After examining the development of the postal rule with its basis, and with the application of above reasoning; it would be a logical and well-reasoned conclusion that postal rule does benefit the email acceptances, and if such rules are going to be applied then the last bastion for this can be emailed. 

The development done for the postal rule would be considered erroneous, as well as, over-complex. Keeping the fact in view that modern technology is increasing its importance in the commercial sphere, it is quite critical that the message is got by the law of contract. 

References of Postal Rule in the UK

Ibrahim, D. M. (2007). The Postal Acceptance Rule in the Digital Age∗. Journal of International Commercial Law and Technology.

Mulcahy et al, L. (2004). Contract Law in Perspective. Psychology Press.

Che, H. (2019). The postal rule in acceptance via email. Commonwealth Law Bulletin, 1–17.

Defossez, D. (2019). Acceptance sent through email; is the postal rule applicable? Law, State and Telecommunications Review, Brasilia, 23-46.

Farry, M. (2002). Concise Contract Law. Pheonix Press.

Griffiths et al, M. (2002). Law for Purchasing and Supply. Prentice-Hall.

LAWTON, L. J. (1974). Retrieved from http://www.bailii.org/ew/cases/EWCA/Civ/1973/5.html

Lawwithdenise. (2018, 11 23). Contract law for Foundation, A-level, Access, Undergraduate and Postgraduate students. Retrieved from http://www.lawwithdenise.net/contract-law/what-is-the-postal-rule

Reeves, K. (2016, Feb 1). A 21ST CENTURY ‘POSTAL RULE’: CAN CONTRACT LAW DELIVER? Retrieved from http://www.keepcalmtalklaw.co.uk/a-21st-century-postal-rule-can-contract-law-deliver/

Yamaguchi, M. (2004). The Problem of Delay in the Contract Formation Process. A Comparative Study of Contract Law’ 37 Cornell International Law Journal.