Taylor v Caldwell [1863]

Beginnings of frustration doctrine.
Contract for use of music hall and gardens.
Hall destroyed by fire.
Got round problem of absolute contractual liability by
using implied condition:
In contracts in which performance depends on continued
existence of given person or thing, condition is implied that impossibility of
performance arising from perishing of person or thing shall excuse performance.
Defendant no longer under obligation, so no breach.