An acceptance may be made either in writing or orally. If in writing, it is held that any form of words which do not in themselves negative the request of the bill should be treated as a valid acceptance.20 The following have been held to constitute a valid acceptance when written on the bill: "Seen;"21 "Presented;" 22 "I will pay this bill,"23 or simply the name of the drawee.24 An acceptance may be made on a separate paper; but in such cases the acceptance must be clear and unequivocal.25

"In jurisdictions where acceptances are not required to be in writing, or the statutes do not otherwise modify the common law, parol acceptances, if assented to by the holder, are permitted. A parol acceptance is any form of words used by the drawee which by reasonable intendment can be made to signify that he honors the bill. There are some limitations to this rule. These words are to be addressed to the drawer or holder. They must be assented to by the holder.

17 Spalding vs. McKay, 5 W. C Q.

B. (U. S.), 656.

18 Smith vs. Milton, 133 Mass., 369.

19 Mountstephen vs. Brooke, 1 B. &

Ald., 224. 20 Leslie vs. Hastings, 1 Moody &

R., 119. 21 Bamet vs. Smith, 10 Frost (N.

H.), 256.

22 Norton on Bills and Notei, Sec.

49; Parson on Bills and Notes, 282 23 Ward vs. Allen, 2 Met. (Mass.), 53. " Spear vs. Pratt, 2 Hill (N. Y.), 582. 25 Coolidge vs. Payson, 2 Wheaton, 66.

They must relate to an existing bill, for, if they pertain to a future bill, they will not be deemed an acceptance. They must be unequivocal, for, if they are equivocal, they will not be deemed an acceptance." 26

An implied acceptance may result from any actions on the part of the drawee which justify the holder in drawing the conclusion that the drawee intends to accept the bill.

An acceptance of a bill may be made before the instrument has been completed as a bill of exchange,27 or after the maturity of the bill,28 in which latter case it is construed as a promise to pay on demand.29 A bill may be accepted after the death of the drawer.'0