The law relating to 'offer' and 'acceptance' is not simple. In Hamilton, Rau and Winthraub on Contracts, the learned authors referred to a decision of Habaska Seed Co. Vs. Harsh 98 Nob 89, 152 NW 310 wherein the purported offer "I want $ 2.25 cent per cent for this seed fobcowell," was held not be an offer on the ground that the defendant did not say "I offer to sell you. At page 346 of the said treatise, it is stated: "The rules of offer and acceptance are usually favourites of law students; they are easily stated and tend to be rather mechanical in their operation. They also involve situations that are relatively easy to grasp and in which various policy consideration are close to the surface. However, one should not assume that one has mastered the law of contracts simply because one is conversant with rules of offer and acceptance. Indeed the writings of modern contracts scholars tend to deprecate the importance of the rules of offer and acceptance. In Halsbury's Laws of England, 4th Edition, Volume-9, the meaning of 'offer' has been stated in paragraph 227 at page 98 in the following terms: Meaning of offer: An offer is an expression by one person or group of persons or by agents on his behalf, made to another, of his willingness to be bound to a contract with that other on terms either certain or capable of being rendered certain. An offer may be made to an individual or to a group of persons or to the world at large. It may be made expressly by words, or it may be implied from the product of the offerer." In Cheshire, Fifoot & Furmston's Law of Contract (14th edition) at Page 62 the law is stated as under:- "It has been established ever since the case of Payne v Cave in 1789 that revocation is possible and effective at any time before acceptance: up to this moment ex hypothesis no legal obligation exists. Nor, as the law stands, is it relevant that the offeror has declared himself ready to keep the offer open for a given period. Such intimation is but part and parcel of the original offer, which must stand or fall as a whole. The offeror may, of course, bind himself, by a separate and specific contract, to keep the offer; but the offeree, if such is his allegation, must provide all the elements of a valid contract, including assent and consideration. In Routledge v Grant the defendant offered on 18 March to buy the plaintiff's house for a certain sum, 'a definite answer to be given within six weeks from the date'. Best CJ held that the defendant could withdraw at any moment before acceptance, even though the time limit had not expired. The plaintiff could only have held the defendant to his offer throughout the period, if he had bought the option by a separate and binding contract."