Introduction to Frustration of Contract: A 1942 Analysis

Understanding contract law can be complex, but landmark cases shed light on practical implications. One such case, pivotal for judiciary aspirants, involves the doctrine of frustration under the Indian Contract Act, of 1872. This case revolves around Section 56, which states that a contract becomes void if its fulfillment becomes impossible or unlawful due to circumstances beyond the parties’ control.


  • The case examines the frustration of contract under the Indian Contract Act, focusing on Section 56.
  • Initially, the Union of India contracted the plaintiffs for Ghee supply to army personnel.
  • Mutual agreement during World War II revised the price downward.
  • The plaintiffs later faced challenges due to increased burdens, seeking a price increase, which the government acknowledged but did not act upon.
  • The core issue was whether to adhere to the original or adjusted price and if the contract became impossible due to unforeseen burdens.

Read about Judicial Work Hours here.

Issues Involved

The case probes into contractual obligations under unforeseen circumstances, focusing on price terms and the doctrine of frustration under Section 56.

Deciphering Frustration of Contract: An Introduction to Section 56 ICA

  • Frustration of contract occurs when unforeseen events make fulfillment impossible, as per Section 56 ICA.
  • It ensures parties aren’t held liable for impossible tasks, which is crucial for judiciary aspirants understanding.

The Dynamics of Contract Modification: A Case Study

  • Contract modification happens with mutual consent, adapting to current needs, as seen in this case.

Evaluating the Validity of Government Assurances in Contractual Agreements

  • The validity of government assurances in contracts requires careful evaluation, especially when they are not formalized.

Interpreting Contracts: The Court’s Perspective on Changed Circumstances

  • Courts balance original intent with changed circumstances in contract interpretation.

The Legal Standpoint on Contractual Obligations and Burdensome Performance

  • Law mandates fulfilling contractual obligations, even when performance becomes burdensome.


The case highlights the importance of mutual agreements in contract modifications and the legal obligation to honor revised terms, showcasing the delicate balance between legal obligations and practical difficulties.


The verdict emphasizes strict adherence to contractual terms despite evolving circumstances, stressing mutual consent and formalization in altering contract terms. It underlines the judiciary’s role in upholding legal principles amidst practical challenges, which is crucial for judiciary aspirants’ understanding and application of the law.