Anglia Television Ltd v. Reed [1972] 1 QB 60
Anglia Television v. Reed is a landmark case in English contract law, particularly concerning the recovery of reliance damages when a contract is breached.
Can a plaintiff recover reliance damages for pre-contractual expenditures when a defendant breaches a contract, especially where specific performance is impossible?
Reliance damages may be awarded to put the plaintiff in the position they would have been in had the contract never been made. These damages can include expenditures incurred both before and after the formation of a contract if those expenditures are wasted as a result of the defendant's breach.
The court held that Anglia Television was entitled to recover the wasted expenses both before and after the formation of the contract because Reed's breach rendered those expenses futile.
This case is pivotal for its expansion of the scope of recoverable damages in contract law, particularly holding that reliance damages can cover pre-contractual expenditures. This doctrine provides a remedy where expectation damages are difficult to ascertain, giving plaintiffs an alternative means of recourse. For law students, Anglia Television v. Reed underscores the importance of considering all forms of damages available in contract cases, particularly when direct losses from a breach are challenging to prove.