Anglia Television Ltd v Reed [1972] 1 QB 60

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Facts

  • A company had a contract with Oliver Reed to act in a film that they hoped would be very profitable
  • Early in filming, Oliver couldn’t finish filming because he was a alcoholic and may well have died.
  • In doing so, the TV company lost a lot of money that it had spent getting the film set ready etc
  • But they could not prove how much profit they were going to make because it was too uncertain

Held

  • The TV company was entitled to damages for the money they had expended.
  • However these were not reliance damages, they were still expectation damages, because the company had expected it would get them back (and more).
  • There is no such thing as reliance damages at Australian law.
  • The onus of proof was on Reid to show that the movie would not have made enough profit to get back the expenditure.

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