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''Chandler v Webster'' 904 1 KB 493 is an
English contract law English contract law is the body of law that regulates legally binding agreements in England and Wales. With its roots in the lex mercatoria and the activism of the judiciary during the industrial revolution, it shares a heritage with countrie ...
case concerning
frustration In psychology, frustration is a common emotional response to opposition, related to anger, annoyance and disappointment. Frustration arises from the perceived resistance to the fulfillment of an individual's will or goal and is likely to incr ...
. It is one of several
coronation cases 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, origina ...
which appeared in the courts after
King Edward VII Edward VII (Albert Edward; 9 November 1841 – 6 May 1910) was King of the United Kingdom of Great Britain and Ireland and Emperor of India, from 22 January 1901 until Death and state funeral of Edward VII, his death in 1910. The second chil ...
fell ill and his coronation was postponed.


Facts

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 (). 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: 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.


Judgment


High Court

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.


Court of Appeal

Lord Collins MR, Romer LJ and Mathew LJ held that Mr Chandler was not entitled to recover his damages before the procession became impossible.


Reform

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.


See also

{{Clist impossibility *
Frustration in English law 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 cont ...
*'' Fibrosa Spolka Akcyjna v Fairbairn Lawson Combe Barbour Ltd''
943 Year 943 ( CMXLIII) was a common year starting on Sunday (link will display the full calendar) of the Julian calendar. Events By place Byzantine Empire * Spring – Allied with the Rus', a Hungarian army raids Moesia and Thrac ...
AC 32 *''
Krell v Henry ''Krell v Henry'' 9032 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 o ...
'' *''
Herne Bay Steamboat Co v Hutton ''Herne Bay Steamboat Co v Hutton'' 9032 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. Facts The defendant, Mr Hutton, contracted to hire a ...
'' English frustration case law Court of Appeal (England and Wales) cases 1904 in case law 1904 in British law