Summary of Anglia Television Ltd. v. Reed
Ct of App. ENGLAND 1971
Facts: ATL hired Reed to be the primary actor in a play that was going to be filmed. ATL agreed to pay Reed £1050, plus £100 a week for board, plus air fare, etc. This was subject to a permit issued from the Ministry of Labour which was received Sept. 2, 1968. Sept 3, 1968 Reed’s agent repudiated his contract because of another contract he was accepting. Reed was acting in another role in an American play. ATL accepted his repudiation and could not find a replacement, the show closed.
Issue: Did the plaintiff rely upon the acceptance of the defendant to such an extent that the costs of both before and after the contract should be bore by the defendant’s breach?
Holding: The Defendant is liable for the damages resulting from ATL’s reliance on his performance both before the contract and after.
Rule: If a contract is broke and expenditures are wasted the breaching party must yield to the damages considered within the offer and acceptance.
Procedure: Master at trial accepted defendant’s liability, but rejected his contention that the only expenditures owed were before not after the contract. Judgment for plaintiff £2,750
Ct. Rationale: The defendant entered into the contract and broke it. The expenditures of ATL were “within the contemplation of the parties when the contract was signed," and as a result of the defendant’s breach the expenditures were wasted, therefore he owes the expenditures before and after the contract.