In Household Fire and Carriage Accident Insurance Co Ltd v Grant (1879), we See the foundation for Chapelton and Berry. The ''meeting of the minds'' is the fulcrum in that instant consumer contractual nexus between the buyer and seller. It is the central point behind the Berry analysis. Carlill is about the meeting of the minds. In Berry, there was no meeting of the minds as to an exclusion clause and exclusion clauses, limiting liability have to be brought to the attention of the contracting party. It could help Gary but his right to sue as a public employee was not excluded but ''Jackie Wilso'' said that the legislation did not apply in Ontario for public employees and used Ontario Public employee legislation to argue while the subject was a national Federal employee who was ''government'' by federal employee legislation. Ontario public employee legislation had no baring upon the case. She was a Federal employee also. This case was not a forum for female authority as riding over the law like a Jezebel and it should not be used as such.

Use in case lawEdit

In Household Fire and Carriage Accident Insurance Co Ltd v Grant (1879) 4 Ex D 216, Thesiger LJ said, in the course of a judgment on the postal rule,

“

Now, whatever in abstract discussion may be said as to the legal notion of its being necessary, in order to the effecting of a valid and binding contract, that the minds of the parties should be brought together at one and the same moment, that notion is practically the foundation of English law upon the subject of the formation of contracts. Unless therefore a contract constituted by correspondence is absolutely concluded at the moment that the continuing offer is accepted by the person to whom the offer is addressed, it is difficult to see how the two minds are ever to be brought together at one and the same moment...[7] But on the other hand it is a principle of law, as well established as the legal notion to which I have referred, that the minds of the two parties must be brought together by mutual communication. An acceptance, which only remains in the breast of the acceptor without being actually and by legal implication communicated to the offerer, is no binding acceptance.

”

In Carlill v Carbolic Smoke Ball Company [1893] 1 QB 256, Bowen LJ said,

“

One cannot doubt that, as an ordinary rule of law, an acceptance of an offer made ought to be notified to the person who makes the offer, in order that the two minds may come together. Unless this is done the two minds may be apart, and there is not that consensus which is necessary according to the English law - I say nothing about the laws of other countries - to make a contract.