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.

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.

Chandler v Webster

On 10 June Mr Chandler wrote to Mr Webster saying:

Chandler v Webster

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.

Chandler v Webster

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

Frustration in English law

Fibrosa Spolka Akcyjna v Fairbairn Lawson Combe Barbour Ltd [1943] AC 32

Krell v Henry

Herne Bay Steamboat Co v Hutton

Notes

English frustration case law

Court of Appeal (England and Wales) cases

1904 in case law

1904 in British law