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In this case (Partridge v Crittenden [1968] 1 WLR 1204) the defendant advertized in a newspaper framble finch cocks and hens 25 shillings each Offering a wild bird for sale is contrary to the Protection of birds act (1954) It was construed that this advertisement was an Invitation to treat, not an Offer in contractual terms, and he was acquited (see: Fisher v bell (1961)).

NB: there is an obiter statement to the effect that supplier's mail order catalogues may give effect to the making of an offer, not an ITT.