## Facts

- Robinson contracted with Harman to receive a lease for a property at £110 per year.
- Harman breached the contract, being unable to grant the lease as promised due to lacking legal right.
- Robinson sought damages for the lost benefit of the bargain.
- The court awarded Robinson £200, reflecting the value of the denied lease, not limited to expenses incurred in anticipation of the lease.

## Issues

1. Whether damages for breach of contract should place the claimant in the position they would have occupied had the contract been performed (expectation interest) or merely restore them to their pre-contractual state (reliance interest).
2. What limitations apply to the recovery of expectation damages, including remoteness, mitigation, and non-pecuniary losses.
3. Whether the measure and reasonableness of damages reflect an economic or moral theory of contract law.

## Decision

- The court held that damages for breach of contract are to be calculated to place the claimant as far as possible in the position they would have occupied if the contract had been performed.
- Robinson was awarded a sum reflecting the benefit of the bargain, not just reliance losses, establishing the expectation damages rule.
- The judgment distinguished expectation damages from reliance damages, highlighting the primacy of the expectation principle for contractual remedies.

## Legal Principles

- The expectation principle: damages should provide monetary compensation to put the innocent party in the position they would have been in had the contract been fulfilled.
- Reliance damages are relevant only when expectation losses are difficult to quantify, but expectation damages remain the primary measure.
- Limitations on expectation damages include the rules on remoteness (damages must be foreseeable), the duty to mitigate losses, the restriction of recovery for non-pecuniary losses, and the awarding of nominal damages where appropriate.
- The extent and measure of damages are subject to reasonableness to avoid disproportionate awards and unjust enrichment.
- The English law of contract emphasizes damages over specific performance, reflecting core theories such as ‘efficient breach’ and supporting economic efficiency alongside contractual sanctity.

## Conclusion

The principle established in Robinson v Harman is that the injured party in a contract breach is entitled to expectation damages, subject to established legal limitations. This rule ensures that compensation reflects the benefit lost through non-performance and is influenced by considerations of reasonableness, remoteness, and mitigation, maintaining the balance between contractual fairness and economic efficiency in English contract law.


Robinson v Harman (1848) 1 Ex 850