44.The only exceptions to this strict view that "impossibility is no excuse" were supervening illegality, death and disability. [23] Later, another exception was formulated in Williams v. Lloyd, W.Jones [24] . This was a case which concerns the destruction of the subject-matter of the contract. The court held that that a bailee's duty to return a horse was discharged when, without the bailee's fault, the horse died, because "that is become impossible the act of God" [25] .