Landmark Cases
Taylor v Caldwell
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Taylor v Caldwell is an 1863 English contract law case, decided by Mr Justice Blackburn of the Court of Queen's Bench, which established the common law doctrine of impossibility, the ancestor of the modern doctrine of frustration. Surrey Gardens Music Hall, which the defendants had contracted to let to the plaintiffs for a series of concerts, burned down before the first concert; Blackburn J held that its continued existence was an implied condition of the contract and that its destruction, the fault of neither party, excused both sides from performance.
Facts
Decision Year Decision Date HoldingHeld that the continued existence of the music hall was an implied condition essential to the contract, and that its destruction by fire, the fault of neither party, rendered performance impossible and excused both parties from their obligations. 1 Current StatusFoundational; opened the door to the modern doctrine of contract frustration, though the ruling itself was narrow. 1 Cross-Tradition Connections
Established
In Legal System
Sources
1. Taylor v Caldwell (Wikipedia)
WikipediaLede (case description)Quote, Lede (case description)
is a landmark English contract law case, with an opinion delivered by Mr Justice Blackburn which established the doctrine of common law impossibility.
1. Taylor v Caldwell (Wikipedia)
WikipediaInfobox (citations field)Quote, Infobox (citations field)
(1863) 3 B & S 826, 122 ER 309
1. Taylor v Caldwell (Wikipedia)
WikipediaInfobox (date decided field)Quote, Infobox (date decided field)
date decided = 6 May 1863
1. Taylor v Caldwell (Wikipedia)
WikipediaJudgment section (final holding sentence)Quote, Judgment section (final holding sentence)
Blackburn J thus held that both parties were excused from their obligations under their contract.
1. Taylor v Caldwell (Wikipedia)
WikipediaImportance sectionQuote, Importance section
This ruling, although quite narrow, opened the door for the modern doctrine of contract avoidance by frustration.
1. Taylor v Caldwell (Wikipedia)
WikipediaEstablished: Frustration of Purpose, Importance section (doctrine origin edge)Quote, Established: Frustration of Purpose, Importance section (doctrine origin edge)
Until this case, parties to a contract were held to be absolutely bound and a failure to perform was not excused by radically changed circumstances. Instead, the contract was breached, and that gave rise to a claim for damages. This ruling, although quite narrow, opened the door for the modern doctrine of contract avoidance by frustration.
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