Coronation cases

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The Coronation cases were a group of appellate opinions in English law cases, all arising out of contracts that had been made for accommodation for viewing the celebrations surrounding the coronation of King Edward VII, originally scheduled for June 26, 1902. The King fell ill, and the Coronation was postponed until August.

The cases included:

Krell v. Henry, [1903] 2 K.B. 740

Defendant agreed to hire a flat from the Plaintiff for June 26th and 27th, 1902. The contract contained no reference to the coronation processions, but they were to take place on those days and were to pass the flat. The processions were cancelled due to the illness of Edward VII and Plaintiff sued to recover rent not already paid. It was HELD by the Court of Appeal that the plaintiff failed; the processions and the location of the flat were the foundation of the agreement and the contract was frustrated.

Herne Bay Steamboat Co. v. Hutton [1903] 2 K.B. 683

Defendant chartered the SS Cynthia from Plaintiff for June 28th and 29th, 1902 for the express purpose of taking paying passengers to see the coronation naval review by Edward VII at Spithead and to tour the assembled fleet. The review was cancelled due to Edward VII’s pneumonia but the fleet remained assembled. The Court of Appeal HELD that the contract was not frustrated. Vaughan Williams and Romer L JJ felt that neither the review nor the tour were at the foundation of the contract (they were matters of importance to the charterer only and not to the owner); Stirling L J felt that both the review and the tour were objects of the contract, and the tour could still be effected.[1]

Hobson v. Pattenden & Co (1903) 19 TLR 186

Clark v. Lindsay (1903) 19 TLR 202

Griffith v. Brymer (1903) 19 TLR 434. In this matter, the parties entered into the contract after the decision had been made (but not publicized) to operate on the King. The contract was ruled to be void, not under the doctrine of frustration as in other Coronation cases, but on the grounds of impossibility.