Oklahoma Statutes
Okla. Stat. tit. 15, § 237 (2026)
Written contract altered, how
✓ current as of July 2026
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A contract in writing may be altered by a contract in writing, or by an executed oral agreement, and not otherwise. R.L.1910, § 988.
Notes of Decisions
Cited in 24
cases (5 in the last 5 years), 1954–2025 · leading case: Richardson v. Mustang Fuel Corp., 772 P.2d 1324 (Okla. 1989).
Richardson v. Mustang Fuel Corp., 772 P.2d 1324 (Okla. 1989). “In the companion case, 3 the Court of Appeals affirmed the trial court’s order denying injunctive relief to those plaintiffs who did not originally reserve the right to purchase gas. We deal here, however, with the landowners who reserved the right to purchase gas in the…”
Creekmore v. Redman Indus., Inc., 671 P.2d 73 (Okla. Civ. App. 1983). “For this proposition, Appellees rely on 15 O.S.1981 § 237, wherein it is stated “a contract in writing may be altered by a contract in writing, or by an executed oral agreement, and not otherwise”.”
DCR Fund I, LLC v. TS Fam. Ltd. P'ship, 261 F. App'x 139 (10th Cir. 2008). “Defendants contend that the banks’ agreement to accept deferred payments constituted “executed oral agreements” under Okla. Stat. tit. 15, § 237 , sufficient to modify the terms of the written loan documents notwithstanding the statute of frauds.”
Cunningham Lindsey Claims Mgmt., Inc. v. Oklahoma State Ins. Fund, 2002 OK CIV APP 7 (Okla. Civ. App. 2001). “The modification of a contract must be done pursuant to the statutory requirements of 15 O.S.1991 § 237, which provides: A contract in writing may be altered by a contract in writing, or by an executed oral agreement, and not otherwise.”
Allen Farms, Inc. v. Broce Const. Co., Inc., 2006 OK CIV APP 36 (Okla. Civ. App. 2005). “5 Allen responds, asserting the evidence showed that it delivered and installed all invoiced sod at the specific direction of Broce and/or its agents, and that Broce bears liability for all sod delivered and installed pursuant to an executed oral modification of the parties’…”
Knittel v. Sec. State Bank, Mooreland, 593 P.2d 92 (Okla. 1979). “In making this argument, the Bank puts great reliance upon the provisions of 15 O.S.1971, § 237, which provide: “A contract in writing may be altered by a contract in writing, or by an executed oral agreement, and not otherwise.”
Kenison v. Baldwin, 351 P.2d 307 (Okla. 1960). “See 15 O.S.1951 § 237; Davis v. Standard Ins.”
Johnson v. Brown, 2024 OK CIV APP 18 (Okla. Civ. App. 2024). “" 15 O.S.2021 § 237. "It is axiomatic that parties to an existing valid contract may, by mutual consent and consideration, modify the contract.”
Bearden v. Smith, 274 P.2d 1015 (Okla. 1954). “To hold otherwise, would be to strike down the force and effectiveness of a written contract, in violation of the provisions of 15 O.S.1951 § 237. The plaintiff failed to establish his right to recover additional compensation and the trial court was correct in sustaining the…”
Bowen v. Freeark, 370 P.2d 546 (Okla. 1962). “The defendants Wrights’ answer pleads in some detail the facts and circumstances surrounding the sale of the property and particularly the alleged conversation with plaintiff prior to the consummation of the sale with Freeark and the silence of plaintiff as to any option…”
Antrim Lumber Co. v. Bowline, 460 P.2d 914 (Okla. 1969). “2d 861 , this court held that: “Under the provisions of 15 O.S.1961 § 237, a contract in writing may be altered by an executed oral agreement, as well as by another contract in writing, so that the provision that no extra work or change in the work shall be made or done except…”
Smith v. Phillips Pipe Line Co., 128 F. Supp. 61 (N.D. Okla. 1955). “To hold otherwise, would be to strike down the force and effectiveness of a written contract, in violation of the provisions of 15 O.S.1951 § 237.” . The general principle is stated in 17 C.”
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