Anglia Television Ltd v Reed [1972]

Court: Court of Appeal

Facts: Anglia TV hired actor Reed for a lead role in a TV show. Reed repudiated the contract, and Anglia TV claimed damages for wasted expenditure, including costs incurred both before and after the contract was made.

Issue: Can reliance damages be claimed for expenses incurred before the contract was formed if they were within the contemplation of the parties?

Held: Lord Denning MR held that Anglia TV could recover the full amount of wasted expenditure, including costs incurred before the contract, as they were within the parties’ contemplation when the contract was formed.

Key Judicial Statement: Lord Denning MR explained that reliance damages can include pre-contractual expenditure if it is foreseeable by the parties that such expenses would be wasted in the event of a breach.

💡Leveluplaw: Parties can claim reliance damages for pre-contractual expenses if it was within the contemplation of the parties that these expenses would be incurred.