| Chandler v Webster | |
|---|---|
 | |
| Court | Court of Appeal |
| Citation(s) | [1904] 1 KB 493 |
| Court membership | |
| Judge(s) sitting | Lord Collins MR, Romer LJ and Mathew LJ |
| Keywords | |
| Frustration | |
Chandler v Webster [1904] 1 KB 493 is an English contract law case, concerning frustration. It is one of the many coronation cases, which appeared in the courts after King Edward VII fell ill and his coronation was postponed.
Mr Webster agreed to let Mr Chandler a room on Pall Mall to watch the king's coronation on 26 June 1902 for £141 15s (equivalent to £15,600in 2020). It was understood between the parties that the money for the room should be paid before the procession. Mr Chandler hired the room with the intention of erecting a stand and selling tickets.
On 10 June Mr Chandler wrote to Mr Webster saying:
I beg to confirm my purchase of the first-floor room of the Electric Lighting Board at 7, Pall Mall, to view the procession on Thursday, June 26, for the sum of £141, 15s., which amount is now due. I shall be obliged if you will take the room on sale, and I authorize you to sell separate seats in the room, for which I will erect a stand. If the seats thus sold in the ordinary way of business do not realize the above amount by June 26, I agree to pay you the balance to make up such amount of £141, 15s.
Mr Chandler paid £100 on 19 June but then the king fell ill. The question was whether the £100 could be recovered by Mr Chandler, or whether Mr Webster could demand the balance.
Wright J held that the plaintiff was not entitled to recover the £100 which he had paid, and that, on the construction of the letter of 10 June, it appeared that the balance was not payable until after the procession, and consequently the defendant was not entitled to recover on the counter-claim.
Lord Collins MR, Romer LJ and Mathew LJ held that Mr Chandler was not entitled to recover his damages before the procession became impossible.
The Law Reform (Frustrated Contracts) Act 1943 provided, among other things, that monies provided in advance of performance of a contract are recoverable in the event of performance being frustrated.
Frustration of purpose, in law, is a defense to enforcement of a contract. Frustration of purpose occurs when an unforeseen event undermines a party's principal purpose for entering into a contract such that the performance of the contract is radically different from performance of the contract that was originally contemplated by both parties, and both parties knew of the principal purpose at the time the contract was made. Despite frequently arising as a result of government action, any third party or even nature can frustrate a contracting party's primary purpose for entering into the contract. The concept is also called commercial frustration.
Krell v Henry [1903] 2 KB 740 is an English case which sets forth the doctrine of frustration of purpose in contract law. It is one of a group of cases, known as the "coronation cases", which arose from events surrounding the coronation of King Edward VII and Queen Alexandra in 1902.
The Coronation cases were a group of appellate opinions in English law cases, all arising out of contracts that had been made for accommodation for viewing the celebrations surrounding the coronation of King Edward VII and Queen Alexandra, originally scheduled for 26 June 1902. The king fell ill with an abscess of the abdominal wall two days before the planned coronation and it was postponed until 9 August.
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Frustration is an English contract law doctrine that acts as a device to set aside contracts where an unforeseen event either renders contractual obligations impossible, or radically changes the party's principal purpose for entering into the contract. Historically, there had been no way of setting aside an impossible contract after formation; it was not until 1863, and the case of Taylor v Caldwell, that the beginnings of the doctrine of frustration were established. Whilst the doctrine has seen expansion from its inception, it is still narrow in application; Lord Roskill stated that it is "not lightly to be invoked to relieve contracting parties of the normal consequences of imprudent bargains".
Herne Bay Steamboat Co v Hutton [1903] 2 KB 683 is a case on the subject of frustration of purpose. It is one of a group of cases arising out of the same event, known as the coronation cases.
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