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Impossibility of performance
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==England and Wales== {{main|Impossibility of performance in English law}} A contract may be frustrated by impossibility of performance.<ref>T Anthony Downes. "Impossibility". Textbook on Contract. Fifth Edition. 1997. Section 11.4.2.1 at [https://archive.org/details/textbookoncontra0000down/page/308/mode/1up p 308].</ref> In 1997, Downes said that impossibility and impracticability were separate in England and Wales, and that impracticability was not usually found to result in frustration.<ref>T Anthony Downes. Textbook on Contract. Fifth Edition. 1997. [https://archive.org/details/textbookoncontra0000down/page/311/mode/1up p 311].</ref> The [[English law|English]] case that established the doctrine of impossibility at [[common law]] is ''[[Taylor v Caldwell]].''<ref>3 B.&S. 826, 122 Eng.Rep. 309 (K.B. 1863).</ref>
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