Harkness v. Hyde - Case Summary

University / Undergraduate
Modified: 22nd Feb 2024
Wordcount: 431 words


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Legal Case Summary

Summary: A significant case in contract law regarding condition precedent and breach of contract.


The case originated from a dispute between Mr.Harkness and Mr.Hyde over oil leases. Mr.Hyde conveyed oil leases to Mr.Harkness in exchange for payment. The agreement stipulated that Hyde would only be liable for breaches of warranties made explicitly in the agreement. When Mr.Harkness discovered that one of the leases didn't hold substantial oil, he sued Hyde for damages.


The main legal question before the courts was the interpretation of the terms of the contract and whether it constituted a condition precedent. Furthermore, it assessed whether Hyde's liability was only limited to explicitly stated warranties and if the lack of oil was a breach of such warranty.


This case is significant in contract law as it addresses the issue of conditions precedent versus warranties. It set a precedent in case law that the terms of a contract must explicitly state the conditions, and if not met, it can lead to the failure of the contract. This case emphasised the importance of carefully drafting contract terms, especially in commercial transactions, and is often referenced in similar disputes.


The U.S. Supreme Court held that the terms of the contract were a condition precedent, and since Hyde did not warrant that the land held oil, Mr.Harkness could not sue for breach of contract. The court stated that Hyde's liability was tied to terms explicitly stated in the contract, and thus, Hyde could not be held liable for something outside these parameters.


  • 'Harkness v. Hyde', 98 U.S. 476 (1878)
  • Rotunda, R.D., 'A guide to the U.S. Supreme Court', Congressional Quarterly (1999)
  • Corbin, A., 'Corbin on Contract Law', West Academic Publishing (1952)

Journalist Brief

In simpler terms, Harkness sued Hyde because he believed Hyde had promised that the land he sold, under an oil lease, held substantial amounts of oil. The court disagreed with Harkness and said that Hyde had never explicitly made such a promise in their agreement. Hence, Harkness couldn't sue Hyde for not delivering on that assumption.


What is the significance of Harkness v. Hyde?

Answer: The case holds significant importance in contract law, particularly concerning warranty and conditions precedent in contracts.

Can Hyde be held liable for the lack of oil?

Answer: No, since the contract didn't explicitly warrant that the land held oil.

What does the case say about contract terms?

Answer: The case highlights the importance of clarity and precision in drafting contract terms.

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