Chandler v Webster [1904] 1 KB 493 is a notable English contract law case that deals with the concept of frustration. It emerged as one of several coronation cases following the postponement of King Edward VII's coronation due to his illness. The case revolves around a contractual agreement for the rental of a room on Pall Mall to watch the coronation procession.
Mr Webster agreed to lease a room to Mr Chandler for £141 15s, with the understanding that the payment should be made before the coronation procession on June 26, 1902. Mr Chandler intended to erect a stand in the room and sell tickets. In a letter dated June 10, Mr Chandler confirmed the purchase of the room for £141 15s, paid £100 on June 19, and authorised Mr Webster to sell separate seats. However, the king fell ill, leading to the question of whether Mr Chandler could recover the £100 or if Mr Webster could demand the balance.
In the High Court, Wright J ruled that Mr Chandler was not entitled to recover the £100 payment. The construction of the June 10 letter indicated that the balance was not payable until after the procession, preventing Mr. Chandler from recovering the amount.
In the Court of Appeal, comprising Lord Collins MR, Romer LJ, and Mathew LJ, the decision was upheld. The court held that Mr Chandler could not recover damages before the procession became impossible due to the king's illness.
The Law Reform (Frustrated Contracts) Act 1943, enacted years later, addressed situations like this case. The Act, among other provisions, established that monies provided in advance of contract performance are recoverable in the event of frustration. This reform aimed to rectify perceived injustices in common law rules related to frustrated contracts.
This case exemplifies the challenges and limitations faced by parties in cases of frustration before legislative intervention. The subsequent enactment of the Law Reform Act of 1943 reflected a commitment to creating a fairer and more equitable legal framework in such circumstances.
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