In the case Harmon v.Dunn,the court addressed the issue of:

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The case Harmon v. Dunn addressed the passing of risk of loss when there is no breach of contract and the goods are held by a bailee. Specifically, the case dealt with the responsibility of a railroad company to compensate a farmer for crop damage caused by a train that caught fire while passing through the farmer's property. The court held that the railroad company was responsible for compensating the farmer as the bailee, despite the absence of any breach of contract.

In the Case Harmon V