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Report to the Uniform Law Conference of Canada on Convention on Contracts for the International Sale of Goods

Professor Jacob S. Ziegel, University of Toronto
July 1981

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Article 23

A contract is concluded at the moment when an acceptance of an offer becomes effective in accordance with the provisions of this Convention.


The common law rule is the same as the rule stated in art. 23. Art. 23 fails to deal with the situation where the precise time of acceptance cannot be readily established, as in the well known case of Brogden v. Metropolitan Ry Co. (1877) 2 A.C. 666 (H.L.) There is no doubt that a binding agreement exists in such a case and the same is presumably true under the Convention.

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Pace Law School Institute of International Commercial Law - Last updated April 23, 1999

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