Anglia Television Ltd. v. Reed – Case Brief
Anglia Television Ltd. v. Reed,  3 All E.R. 690.
Facts: Anglia (P) made preparations to produce a play for television titled “The Man in the Wood”. Anglia contracted with Robert Reed (D) to star in the production. Reed agreed to come to England and be available from September 9-October 11, 1968 to rehearse and act in the film in exchange for 1,050 pounds, a living expense of 100 pounds per week, and first class air fare between England and the United States.
D repudiated the contract and informed P that he was booked for another play and would not be available for P’s film. P sued D and sought wasted expenditure but not lost profits. The trial court allowed P to recover all of its damages from both before and after D repudiated the contract and D appealed.
Issue: What damages are available to a plaintiff in a claim for wasted expenditure arising from breach of contract?
Holding and Rule: A plaintiff is not limited only to expenditures incurred after the formation of the contract in a claim for wasted expenditure from a breach of contract.
The court held that if the expenditures incurred before the parties entered into the contract were reasonably within the contemplation of the parties as likely to be wasted if the contract were to be broken, that expenditure is recoverable. The court held that in this case D knew or should have known that if he repudiated the contract, fees incurred for directors and other expenses would be wasted.
Notes: The court awarded Anglia reliance damages based not on contract performance but on the entire event.