In the case of Howell v. Coupland, (1876) 1 QBD 258, the defendant and the plaintiff had made a deal for the sale of 200 tonnes of potatoes. The defendant’s land was to be used for growing the potatoes that were required. To follow the terms of the contract, the defendant planted potatoes on his property, but through no fault of his own, the crop was harmed by a disease. After that, he was limited to providing 8 tonnes of potatoes.
It was decided that neither party was to blame because the performance had become impossible to achieve.
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