Example of breach of warranty
By Uke · 8 November 2026 · 4 min read
Before analysing this case, I need to clarify something important: I could not verify a reported Nigerian or English decision titled Esther v. James from the available legal databases. I do not want to give you invented facts, a false court decision or an incorrect citation.
However, I can demonstrate the proper approach to analysing a case on breach of warranty, using an established Nigerian Supreme Court authority.
1. Example of Case Analysis: Henry Stephens Engineering Co. Ltd. v. Complete Home Enterprises Nigeria Ltd. (1987)
Court: Supreme Court of Nigeria Year: 1987 Subject Matter: Breach of Warranty; Sale of Goods; Damages.
A. Facts of the Case
The case concerned the sale of a crane by Henry Stephens Engineering Company to Complete Home Enterprises Nigeria Limited.
A dispute arose concerning the quality of the crane supplied and the seller's obligations under the contract.
The buyer complained about the defective nature of the crane and sought remedies arising from the breach of the contractual obligations relating to the quality of the goods.
The dispute eventually reached the Supreme Court, which considered the appropriate measure of damages for breach of warranty.
B. Issues for Determination
The central issues included:
1. Whether there was a breach of warranty concerning the quality of the goods supplied.
2. Whether the buyer was entitled to recover damages for the breach.
3. What constituted the proper measure of damages for breach of warranty.
4. Whether the buyer could recover the purchase price in addition to damages.
C. Decision of the Court
The Supreme Court explained the legal principles governing damages for breach of warranty.
The Court emphasised that the proper measure of damages for breach of warranty of quality is ordinarily the difference between:
The actual value of the goods at the time of delivery; and
The value the goods would have had if they had complied with the warranty.
The Court also recognised that consequential losses may be recoverable where properly established.
Importantly, a buyer cannot simply obtain a refund of the purchase price merely because there has been a breach of warranty. The appropriate remedy depends on the nature of the claim and the applicable legal principles.
D. Legal Principle (Ratio Decidendi)
The principle established is that:
In an action for breach of warranty relating to the quality of goods, the measure of damages is prima facie the difference between the actual value of the goods at the time of delivery and the value they would have possessed if they had complied with the warranty.
The decision also demonstrates that damages must be properly established and that a claimant cannot obtain double compensation for the same loss.
E. Relevance to Breach of Warranty
This case is relevant because it explains the remedies available to a buyer where goods supplied do not conform to the warranty given by the seller.
It distinguishes between the right to claim damages and the right to recover the purchase price.
Authority: [Henry Stephens Engineering Co. Ltd. v. Complete Home Enterprises Nigeria Ltd. (1987)](https://nigerialii.org/akn/ng/judgment/ngsc/1987/5/eng%401987-01-16?utm_source=chatgpt.com)
---
2. How to Analyse Esther v. James in an Examination
When analysing Esther v. James, use the following structure:
Heading What to discuss
Case name Esther v. James Court and year State the court and year of judgment Facts Briefly explain what happened between the parties Issues Identify the legal questions before the court Decision Explain what the court decided Ratio decidendi State the legal principle established Relevance Connect the decision to breach of warranty
3. Understanding Breach of Warranty
A warranty is a contractual term that is subsidiary to the main purpose of a contract.
Under the traditional classification of contractual terms, its breach ordinarily entitles the innocent party to damages but does not automatically entitle that party to terminate the contract.
For example:
James agrees to sell Esther a refrigerator for ₦300,000. During negotiations, James expressly assures Esther that the refrigerator has a one-year warranty covering manufacturing defects.
Two months after purchase, the refrigerator develops a manufacturing fault. James refuses to honour the warranty.
James may be liable for breach of warranty because he failed to fulfil an express contractual undertaking.
Esther may seek appropriate damages or other remedies available under the applicable law.
---
One thing I need from you
Is Esther v. James the exact name of the case in your lecture note?
If you upload a picture of the case or provide its full citation, I can give you its actual facts, issues, arguments of counsel, judgment, ratio decidendi and relevance to breach of warranty without confusing it with another authority.