Bloom v The American Swiss Watch Company (1915 AD 100)

Bloom v The American Swiss Watch Company (1915 AD 100)

Facts

Jewelry to the value of 5,000 pounds was stolen from the American Swiss Watch Company. The following day, the Company offered a reward of 500 pounds for information leading to the arrest of the robbers and recovery of the stolen property. Bloom furnished such information, but it was found by Judge Hopley that Bloom did not know about the reward. It was held that Bloom's case was dependent on establishing a contractual relationship between him and the company. Since the offer was public, it was still required that someone accept it to conclude a contract. Bloom did not give the information on the faith of the offer, so no vinculum could be established.

Issue

Whether Bloom had entered into a contract with the American Swiss Watch Company by providing information leading to the arrest of the robbers and recovery of the stolen property, even though he was not aware of the reward.

Reasons

The Appellate Division of the Supreme Court of South Africa held that Bloom had not entered into a contract with the American Swiss Watch Company. The court found that the offer of a reward was a unilateral offer, and that acceptance of the offer required communication of the acceptance to the offeror. Since Bloom was not aware of the reward at the time he provided the information, he could not have communicated his acceptance of the offer to the American Swiss Watch Company.

Unilateral offer

A unilateral offer is an offer that is accepted by performance of the act requested in the offer. Bloom's performance of the act requested in the offer (providing information leading to the arrest of the robbers and recovery of the stolen property) would have constituted acceptance of the offer, if Bloom had been aware of the offer at the time of performance.

Communication of acceptance

Acceptance of a unilateral offer must be communicated to the offeror. This is because the offeror needs to know that their offer has been accepted in order to be bound by the contract. Bloom did not communicate his acceptance of the offer to the American Swiss Watch Company because he was not aware of the offer at the time of performance.

Conclusion

The court held that Bloom had not entered into a contract with the American Swiss Watch Company because he had not accepted the offer of a reward.

Summary

The case of Bloom v The American Swiss Watch Company (1915 AD 100) is a landmark case in South African contract law. The case is particularly important for its analysis of the following issues:

• The requirements for a valid contract;
• The concept of a unilateral offer; and
• The requirement of communication of acceptance.

Requirements for a valid contract

The case established that there are three requirements for a valid contract:

1. Offer and acceptance;
2. Consideration; and
3. Intention to create legal relations.

Unilateral offer

The case established that a unilateral offer is an offer that is accepted by performance of the act requested in the offer.

Requirement of communication of acceptance

The case established that acceptance of a unilateral offer must be communicated to the offeror.

Impact of the Case

The case of Bloom v The American Swiss Watch Company (1915 AD 100) has had a significant impact on the law of contract in South Africa. The case has clarified the requirements for a valid contract, the concept of a unilateral offer, and the requirement of communication of acceptance.