Addis v Gramophone Co Ltd (1909) is one of the UK labor law and English contract law cases. This labor law case was used to confine indemnity for the non-pecuniary for breach of contract.
Mr. Addis was the manager of Gramophone in Calcutta, India.

He was given the notice of six months and was appointed as a successor. For preventing Mr. Addis, they had taken some measures and it was insulting. Then the jury honored Mr. Addis £340 as a loss of commission as well as £600 for a wrongful discharge.

The Court of Appeal permitted indemnity for the way of the dismissal.

Lord Loreburn said that the damages of £600 was not granted and Mr. Addis could only recover salary for six months and not more than that; because company can’t give a larger commission for unlawful dismissal for an employer who was paid a small salary.

After this he said, if there is a dismissal without notice, then the employer must give an indemnity. Further he added, indemnity can’t include compensation for the ill-treated feelings of the employer.

After the case, Sir Frederic Pollock, the Law Quarterly Review’s editor, differentiated ‘the rationale of the matter’ from ‘an artificial rule or mere authority’.It is as follows –

When there is a case of unlawful dismissal, in a harsh as well as humiliating manner and the implementation of such dismissal may create complications for the employer to achieve a new position. In Addis v Gramophone Co Ltd case, the claimant was discharged immediately from the important post in India. Then the entire management was removed from Mr. Addis’s authority, in such a manner which might not show any kind of humiliation and which could not harm him leading to a permanent loss. The entire issue was all about quantum of damages.