Islamic jurisprudence "fiqh" was the first legal system which adopted the doctrine of offer and acceptance. It is thought that the doctrine had been imported to French legal system from Islamic Fiqh through Spain and then transmitted to English law.

As we have seen, all the legal systems which have been studied are in common on the question of determination of offer and acceptance. This determination is based on a chronologically sequential order: the first expression of one party's will is an offer while the second corresponding expression of the other party's will is an acceptance. Nevertheless, all these systems acknowledge some variations from this pattern. These variations vary from one system to another.

As to Jordanian Civil Code, the heavy influence of Islamic Fiqh on it has affected the way by which the code dealt with the doctrine.

In fact, the articles concerning offer and acceptance were taken verbatim from the Majallah, Murshid AL- Hairan and Egyptian Civil Code. The legislator thought that Islamisation of civil code means a mere collection of Islamic rules. They failed to coordinate these texts, bring them together, lay down a basic rule and leave much of details to courts.

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