This section is from the book "The Law Of Contracts", by William Herbert Page. Also available from Amazon: Commercial Contracts: A Practical Guide to Deals, Contracts, Agreements and Promises.
Even if tender may be made after default, it can not be made after action has been commenced in the absence of some statutory provision or rule of court which authorizes such tender.1 Such tender has no effect on costs which have accrued before such tender is made.2 Under many statutes, however, tender may be made after action has been brought if the principal and interest and costs down to the time of tender are offered in accordance with the requirements of the statute;3 and this usually includes the production of the money in court or payment into court.
Even if tender may be made at any time before trial, tender after trial has begun and verdict has been rendered is inoperative.4
 
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