## Facts

- The case involved a contract for the rental of a music hall for a series of concerts.
- Before the concerts could take place, the hall was destroyed by fire, through no fault of either party.
- The claimant, having contracted to use the hall, sued for breach of contract.
- The court had to consider whether the destruction of the hall excused both parties from their contractual obligations.

## Issues

1. Whether the destruction of the subject matter (the music hall), without fault by either party, discharged the contractual obligations.
2. Whether a contract should be treated as absolute or subject to implied conditions about the continued existence of a specific thing.
3. What standard should guide courts in excusing performance due to unforeseen events beyond the parties’ control.

## Decision

- The court held that the destruction of the music hall, without fault of either party, excused both parties from further performance of their contractual obligations.
- Justice Blackburn introduced the concept of implied conditions: if performance depends on the continued existence of a specific thing, the contract is subject to an implied condition that if the thing perishes, performance is excused.
- The decision marked a shift away from the rigid doctrine of absolute contracts toward considering the implicit assumptions of contractual performance.

## Legal Principles

- The doctrine of frustration arises when an unanticipated event, beyond either party’s control, fundamentally alters the nature of contractual performance.
- Frustration requires that the event makes performance impossible or radically different from what was originally contemplated.
- A contract is discharged if its main purpose or subject matter no longer exists due to such unforeseen events.
- The doctrine does not excuse performance if the event was reasonably foreseeable or caused by one of the parties (self-induced frustration).
- Later case law clarified that mere inconvenience, increased cost, or delay is insufficient; the change must go to the root of the contract.
- The doctrine has been further refined through cases such as National Carriers Ltd v Panalpina (Northern) Ltd, Davis Contractors v Fareham UDC, Krell v Henry, and Herne Bay Steamboat Co v Hutton, focusing on "radical change" and "frustration of purpose".

## Conclusion

Taylor v Caldwell established the basis for the doctrine of frustration in English contract law, ruling that parties are excused from contractual obligations when an unforeseen event—such as the destruction of the contract’s subject matter—renders performance impossible or fundamentally different, provided that event was neither foreseeable nor self-induced.


Taylor v Caldwell (1863) 3 B & S 826