Citation(s) [1972] 1 QB 60 | ||
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Ruling court Court of Appeal of England and Wales Similar Jarvis v Swans Tours Ltd, Ruxley Electronics and Cons, Farley v Skinner, Robinson v Harman, Addis v Gramophone Co Ltd | ||
Anglia Television Ltd v Reed [1972] 1 QB 60 is an English contract law case, concerning the right to reliance damages for loss flowing from a breach of contract.
Contents
Facts
Anglia asked Robert Reed – Mike Brady, the dad from the Brady Bunch – to star in their TV film, The Man in the Wood, about an American man married to an English woman who has an adventure in an English wood. Reed withdrew just before filming was about to start. Anglia did not claim for loss of profits, because that was too uncertain. Instead they claimed wasted expenditure. Reed argued, based on Tindal CJ in Hodges v Earl of Litchfield (1835) 1 Bing NC 492, 498 that damages could not be claimed when incurred before a contract, that was wasted, thrown away.
Judgment
Lord Denning MR held that expenditure incurred before could be claimed, so long as it was within the contemplation of the parties. Here Reed would have known of considerable expense.
So not £854.65 awarded (after) but the full £2750 (before as well) for all the directors, designers, stage managers and assistant managers' fees.