parties to impose extra damages for a breach. Alderson B said the following: Significance Lon L. Fuller and WR Perdue evaluated the idea of reducing contractual remoteness to foreseeability in this way: As early as 1894, the U.S. Supreme Court recognized the influence of Hadley upon American law: The Hadley holding was later incorporated into Section 351 of the Restatement (Second) of Contracts. A 1994 law review article noted that as of that year, Hadley had been cited with approval by the state supreme courts of 43 U.S. states; three state supreme courts had adopted the Hadley holding without citing Hadley itself; and intermediate appellate courts in the four other states had also favorably cited Hadley. In Satef-Huttenes Albertus SpA v Paloma Tercera Shipping Co SA (The Pegase) [1981] 1 Lloyd’s Rep 175, Robert Goff J stated, However, it has been suggested that the rule in Hadley v Baxendale is not as novel as its celebrated importance suggests. James Edelman, a Justice of the High Court of Australia gave a speech on the topic, asserting that "the rule set out in Hadley v Baxendale was not novel". For example, Edelman noted that, in 1564, the French jurist Charles Dumoulin had argued that liability for breach of contract should be limited to foreseeable damage, thereby pre-dating this same sentiment in Hadley v Baxendale. The core of the judgment below is often cited as an example of a combination of the objective test and a subjective test: See also Victoria Laundry (Windsor) Ltd v Newman Industries Ltd [1948] 2 KB 528 Koufos v Czarnikow Ltd or The Heron II [1969] 1 AC 350 Parsons (Livestock) Ltd v Uttley Ingham & Co Ltd [1978] 1 QB 791 South Australia Asset Management Co v York Montague [1996] 3 All ER 365 Jackson v Royal Bank of Scotland [2005] 2 All ER 71 The Achilleas [2008] UKHL 48 Notes External links Judgment of Alderson B pdf file hosted by mtsu.edu Judgment available via Bailii (abridged) English Reports version available via Google Books Historical background of case Picture of Hadley's mill 1854 in case law English remedy case law 1854 in British law Court of Exchequer Chamber cases