Have you ever found something valuable and wondered if you could claim the reward, even though you were already looking for it? That’s exactly the legal quandary at the heart of the fascinating case of Lalman Shukla v. Gauri Datt—a cornerstone ruling that continues to influence contract law across India and beyond.
The Curious Case of the Missing Nephew
January 1913 brought worry to the household of Gauri Datt when his nephew vanished without a trace. Desperate to find the boy, Datt mobilized his employees, sending them in all directions to locate the missing child.
Among these searchers was Lalman Shukla, a trusted employee who worked as a munib (clerk) in Datt’s firm. Shukla received specific instructions to travel to Hardwar, along with money for his railway fare and daily expenses. His mission was clear: find the missing boy.
After Shukla had already departed, Datt intensified his search efforts by issuing handbills offering a substantial reward of Rs. 501 to anyone who could locate his nephew. Some of these handbills eventually reached Hardwar, where Shukla was searching.
The Discovery and Aftermath
Through diligent effort, Shukla managed to track the boy to Rishikesh. He immediately telegraphed Datt, who rushed to Hardwar and joyfully reunited with his nephew before bringing him back to Cawnpore (modern-day Kanpur).
In recognition of Shukla’s efforts, Datt gave him two gold sovereigns as a token of appreciation and later added twenty rupees more. Shukla accepted these gifts without protest and continued working for Datt for approximately six months afterward.
The story might have ended there, but when Shukla was eventually dismissed from service, he filed a lawsuit demanding Rs. 499—the remainder of the advertised reward after subtracting the value of the gifts he’d received.
The Legal Battle Unfolds
In court, Shukla initially claimed Datt had explicitly promised him the reward money in addition to travel expenses when sending him to Hardwar. The court quickly determined this allegation was false, as the handbills were printed only after Shukla had left for Hardwar.
When this approach failed, Shukla’s legal strategy shifted. His new argument was elegantly simple: he had performed the exact action requested in the advertisement (finding the boy), so he deserved the promised reward—regardless of whether he knew about the reward beforehand or what his motives were.
The Crucial Legal Question
Judge Banerji faced a fundamental question about contract law: Could someone claim a reward for performing an action they were already obligated to do?
This case forced the court to examine the very essence of what makes a contract valid:
- Offer and acceptance – Did Shukla actually “accept” the offer if he was already searching before it was made?
- Knowledge of the offer – Can someone accept an offer they didn’t know existed?
- Consideration – Does performing an action you’re already required to do constitute valid consideration for a new contract?
Conflicting Precedents and Legal Principles
Shukla’s counsel cited two English cases to support his position:
- Williams v. Carwardine (1833)
- Gibbons v. Proctor (1891)
Both cases suggested that merely performing the requested act was sufficient to claim a reward, regardless of one’s knowledge or motives.
Judge Banerji, however, noted these cases had faced significant criticism from legal scholars like Sir Frederick Pollock and American author Ashley. The judge sided with these critics, emphasizing that a contract requires both knowledge of the offer and intention to accept it.
He specifically referenced Section 8 of the Indian Contract Act, which states that “performance of the conditions of a proposal is an acceptance of the proposal.” This implies that one must know about the proposal to accept it through performance.
The Pre-existing Duty Rule
The court’s reasoning introduced what would become known as the “pre-existing duty rule” into Indian contract law. Judge Banerji reasoned:
- Shukla was Datt’s employee.
- He was specifically sent to search for the boy.
- This created an obligation to perform this search.
- This obligation existed before the reward was offered.
- Therefore, finding the boy was merely fulfilling a pre-existing duty, not providing fresh consideration for a new contract.
The judge concluded: “Being under that obligation, which he had incurred before the reward in question was offered, he cannot, in my opinion, claim the reward. There was already a subsisting obligation and, therefore, the performance of the act cannot be regarded as a consideration for the defendant’s promise.”
Why This Case Matters Today
The Lalman Shukla case established critical principles that continue to shape contract law:
- Knowledge is essential – You cannot accept an offer you don’t know exists.
- Intention matters – Merely performing an act without intending to accept an offer doesn’t create a contract.
- Pre-existing duties – Performing actions you’re already obligated to do doesn’t constitute fresh consideration.
This case serves as a powerful reminder that contract formation requires meeting specific elements—offer, acceptance, consideration, and intention to create legal relations. It also highlights the principle that employees cannot generally claim rewards for actions within their scope of employment.
The Modern Application
Today’s legal landscape still reflects these principles. For instance:
- A police officer cannot claim a reward for catching a criminal.
- An employee cannot demand extra payment for completing assigned tasks.
- A contractor cannot claim additional fees for work already covered in the original agreement.
The next time you see a “reward offered” poster, remember Lalman Shukla’s case. The right to claim that reward may depend not just on finding what’s lost, but on whether you were already obligated to look for it in the first place.