판결 이유
A contract is not frustrated merely because an event that formed one party's motive for entering the contract fails to occur. Frustration only applies where the supervening event destroys the foundation or common purpose of the contract for both parties, not merely one party's particular purpose.
사실관계
Hutton hired a steamboat from Herne Bay to take paying passengers to see the royal naval review at Spithead and to cruise around the fleet on the occasion of Edward VII's coronation. The naval review was cancelled because the King fell ill. Hutton refused to pay, arguing the contract was frustrated.
판결 요약
The Court of Appeal held the contract was not frustrated. The naval review was not the sole foundation of the contract — the boat could still cruise around the fleet. The coronation was the motive of Hutton, not a condition of the contract. This was distinguished from Krell v Henry [1903], where the flat had been hired solely for the purpose of viewing the coronation procession.
주요 인용문
"The ship could still be used to cruise around the fleet, and that was part of the purpose of the hire."
— Vaughan Williams LJ
후속 처리
Contrasted with Krell v Henry [1903] to illustrate the narrow scope of frustration — the event must be the foundation of the contract, not merely one party's purpose.