Ratio Decidendi
A person who is not a party to a contract cannot sue upon it, even if the contract was made for their benefit. Only a party to a contract can enforce it (the doctrine of privity).
ข้อเท็จจริง
William Tweddle married the daughter of John Atkinson. Before the wedding, Tweddle's father and Atkinson agreed that each would pay a sum of money to the couple. Atkinson died before paying. Tweddle sued Atkinson's executor to enforce the promise.
สรุปคำพิพากษา
The court held that Tweddle could not enforce the agreement because he was not a party to the contract between his father and Atkinson, and had provided no consideration. The doctrine of privity prevented enforcement by a third-party beneficiary.
คำกล่าวสำคัญ
"No stranger to the consideration can take advantage of a contract, although made for his benefit."
— Wightman J
การอ้างอิงภายหลัง
The Contracts (Rights of Third Parties) Act 1999 allows third parties to enforce terms made for their benefit, significantly limiting (but not overruling) the privity doctrine.