In the case of a breach of a contract to deliver property the measure of damages is generally held to be the value of the property,6 or if the goods have not been paid for, the difference between the contract price of the goods and what they can be purchased for elsewhere.7

Where property is wrongfully converted to the use of another, the measure of damages is generally held to be the value of the property at the time of the conversion, with interest from the date of such conversion.8 In the case of goods of a fluctuating value some courts have held the measure of damages to be the highest intermediate value between the time of the conversion and the trial.9