Chandler v Webster – Case Summary

Chandler v Webster

Court of Appeal

Citations: [1904] 1 KB 493.


King Edward VII was crowned in 1902. The defendant let a room to the claimant to view the coronation procession. The procession was supposed to take place on June 26. The claimant paid most of the fee in advance, but delayed in paying the remainder. The King became ill and procession did not take place.

The claimant sued to recover the money that he had paid. He argued that that the contract was frustrated. The defendant counter-sued for the remainder of the fee.

  1. Was the contract frustrated?
  2. Was the claimant obliged to pay the remainder of the fee?
  3. Could the claimant obtain a refund of the money already paid?

The Court of Appeal held in favour of the defendant. The obligation to pay arose before the procession was cancelled. Therefore, even if the contract was frustrated the claimant was bound to pay the remaining fee. He was not entitled to a refund of what he had already paid.

This Case is Authority For…

Frustration does not render a contract void. Obligations which become live before the frustrating event are still actionable after the contract is frustrated. Similarly, the parties can sue each other for breaches which occurred prior to the frustrating event. Frustration only releases parties from obligations which arise after the frustrating event.


The court implied that the contract had been frustrated, it just was not relevant to whether the claimant had to pay the fee. This is therefore one of the rare examples where a contract which was technically possible to perform (the claimant could have gone and used the room) was frustrated. This was because it was objectively apparent that the contract had a particular commercial purpose (seeing the procession) on which it was based. That purpose had been frustrated.