Krell v. Henry 1903 (Case Summary)

In this case, the Court of Appeal addressed the doctrine of frustration of contract. The case established that a contract is discharged when its fundamental purpose is destroyed by an unforeseen event, even if performance is technically possible.

Facts of Krell v. Henry

1. The defendant, Henry, agreed to rent a room from the plaintiff, Krell, to view the coronation procession of King Edward VII.
2. The agreement was for June 26 and 27, 1902, with the coronation procession being the key reason for the rental.
3. Before the agreed dates, the coronation procession was canceled due to the King’s illness.
4. Although the room was still available for use, the purpose of the contract (viewing the coronation) was frustrated.
5. Henry refused to pay the remaining rent, arguing that the cancellation of the procession made the contract void.
6. Krell sued for the unpaid balance.

Issues framed

1. Whether the cancellation of the coronation procession frustrates the contract, discharging the parties from their obligations?
2. Whether a contract can be enforced when its primary purpose is destroyed by an unforeseen event?

Subordinate Court Judgment

The trial court ruled in favor of Henry, holding that the cancellation of the coronation procession frustrated the purpose of the contract, making it unenforceable.

Krell appealed to the Court of Appeal.

Judgment of Krell v. Henry

The Court of Appeal addressed the doctrine of frustration of contract. A contract is frustrated when an unforeseen event renders its fundamental purpose impossible to achieve.

The court held that the primary purpose of the contract was to provide a vantage point for viewing the coronation procession. The cancellation of the procession destroyed the foundation of the agreement, even though the room was still physically available.  The court reasoned that the procession’s occurrence was an implied condition of the contract. Its cancellation frustrated this condition, discharging the contract.

The Court of Appeal dismissed Krell’s appeal, holding that the contract was frustrated due to the cancellation of the coronation procession. Henry was not liable to pay the remaining rent.

 The doctrine of Frustration in Indian contract law is codified under Section 56 of the Indian Contract Act, 1872, which states that a contract becomes void when an unforeseen event makes its performance impossible or unlawful.