Minneapolis Steel & Machinery Co. of Canada Ltd. v. Baxter Brothers

Minneapolis Steel & Machinery Co. of Canada Ltd. v. Baxter Brothers

The courts found as a fact that the contract was not completed until May 10, 1920; consequently s.31 of the Farm Implement Act applied, rendering the contract invalid and defeating the plaintiff's claim.

Citation
[1928] SCR 62
Parties
Plaintiff (appellant): Minneapolis Steel & Machinery Co. of Canada Ltd.; Defendant (respondent): Baxter Brothers et al.
Court
Supreme Court of Canada
Jurisdiction
Canada
Judgment Date
20 April 1927
Procedural Posture
Contract / On Appeal to the Supreme Court of Canada From the Court of Appeal for Saskatchewan
Outcome
Appeal dismissed with costs.
Legal Topics
Formation of Contract, Postal Rule / Mailing Deposit, Compliance With Statutory Formalities, Farm Implement Act S.19 and S.31
Source Language
English
Contract Statutory Interpretation Formation of Contract Postal Rule / Mailing Deposit Compliance With Statutory Formalities Farm Implement Act S.19 and S.31

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Parties

Minneapolis Steel & Machinery Co. of Canada Ltd.

Plaintiff (appellant)

Baxter Brothers et al.

Defendant (respondent)

Procedural Posture

Contract / On Appeal to the Supreme Court of Canada From the Court of Appeal for Saskatchewan

Legal Issues

  1. 1 Whether the contract was completed by deposit/mailing of a copy in the post office to the purchaser on or before March 31, 1920
  2. 2 Whether s. 31 of the Farm Implement Act applies to invalidate the contract
  3. 3 Whether the requirements of s. 19 (signature by vendor and deposit in post office, postage prepaid and registered) were satisfied by the appellant

Ratio Decidendi

The courts found as a fact that the contract was not completed until May 10, 1920; consequently s.31 of the Farm Implement Act applied, rendering the contract invalid and defeating the plaintiff's claim.

Court Disposition

Appeal dismissed with costs.

Orders

  • Appeal dismissed with costs.