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Daulia Ltd v Four Millbank Nominees Ltd

[1978] 2 All ER 557


On the issue of acceptance in cases of unilateral contracts:

"Whilst I think the true view of a unilateral contract must in general be that the offeror is entitled to require full performance of the condition which he has imposed and short of that he is not bound, that must be subject to one important qualification, which stems from the fact that there must be an implied obligation on the part of the offeror not to prevent the condition becoming satisfied, which obligation it seems to me must arise as soon as the offeree starts to perform.  Until then the offeror can revoke the whole thing, but once the offeree has embarked upon performance it is too late for the offeror to revoke his offer.”