Question:medium

In which case it has been laid down that a promise to pay subscription is binding on the promisor if promisee has undertaken some liability on the faith of the promisee:

Updated On: Jul 13, 2026
  • Lalman Shukla v. Gauri Dutt
  • Kedar Nath v. Gorie Mohd
  • Bhagwandas v. Girdhari Lal
  • Banwari Lal v. Sukhdarshan Dayal
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The Correct Option is B

Solution and Explanation

Subscription promises come up often in contract law because, on their face, they look like one-sided gifts with nothing given in return. The doctrine that fixes this gap is best understood by first asking what actually supplies the consideration.

  1. Lalman Shukla v. Gauri Dutt: the consideration issue in this case was about knowledge of the offer at the time of acting on it, not about subscriptions or reliance-based liability, so it answers a different legal question.
  2. Kedar Nath v. Gorie Mohd: the consideration here was found not in the subscriber's promise standing alone, but in the fact that the person collecting subscriptions went ahead and entered a binding contract with a builder on the faith of the promised amounts. Once that liability was undertaken, the subscriber could no longer walk away from the promise. This is precisely the situation the question describes.
  3. Bhagwandas v. Girdhari Lal: this case fixes the place where a contract is made over instantaneous communication, a question of jurisdiction and timing, not of what makes a subscription promise enforceable.
  4. Banwari Lal v. Sukhdarshan Dayal: nothing in the settled doctrine on subscription promises points to this case as the authority, the reliance-based rule is tied specifically to Kedar Nath.

Locating where the consideration actually comes from, the promisee's own change of position, leads straight to the Kedar Nath ruling.

The correct answer is Kedar Nath v. Gorie Mohd.

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