Krell vs Henry Case summary
Facts:
Henry agreed to rent rooms from Krell for £75 to watch King Edward VlI's coronation procession on June 26, 1902. The contract specified the rooms purpose: viewing the procession. The coronation was postponed due to the King's illness. 4Henry refused to pay hence Krell sued for rent.
Issue:
Can a contract be discharged due to frustration when the contemplated event (coronation procession) does not occur?
Key legal concepts:
1. Doctrine of frustration:
It states that a contract can become void if it becomes impossible to fulfil due to unforeseen events.
2. Force majeure
3. Discharge of contract
4. Impracticability
Sec. 56 of Indian Contract Act-
Judgment:
Lord Justice Vaughan Williams:
“…the coronation procession was the foundation of the contract… the non-occurrence of that event frustrated the contract.”
Court reversed the lower court’s decision and held that the contract was frustrated and discharged.
Consequences:
1. Krell’s claim for rent dismissed
2. Henry relieved of contractual obligations.
3. Established precedent for frustration doctrine.
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