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Victoria Laundry v Newman Industries [1949]


  • The defendants were 30 weeks late in delivering new boilers to the claimants
  • This late delivery meant that the claimants could not accept some particularly lucrative Government contracts


  • Could damages be awarded for loss of profits from the lucrative contracts?


  • No


  • Damages awarded for ‘normal’ profit loss only as defendants were unaware of lucrative contract loss certainty
  • Hadley v Baxendale [1854] is a two limb test, normal then special tests
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