Ramsgate Victoria Hotel Co v Montefiore
(1866) LR 1 Ex 109
Ratio Decidendi
An offer to purchase shares (or other offer) lapses after a reasonable time. What constitutes reasonable time depends on the subject matter and circumstances.
Facts
In June 1864, Montefiore applied for shares in the hotel company, paying a deposit. He heard nothing until November, when the company allotted the shares and demanded the balance. Montefiore refused to pay.
Judgment Summary
The court held that the offer had lapsed due to the passage of an unreasonable time (five months). An offer does not remain open indefinitely; it expires after a reasonable time if not accepted.
Key Quotes
"The offer was not accepted within a reasonable time and the defendant was therefore justified in refusing the shares."
— Pollock CB
Subsequent Treatment
Leading authority on lapse of offers after a reasonable time.