判决理由
A third party cannot enforce a contract to which they are not a party (privity of contract). However, a party to the contract can obtain specific performance for the benefit of a third party where damages would be inadequate.
事实
Peter Beswick agreed to transfer his coal business to his nephew John, in return for John paying Peter a weekly sum during his lifetime and thereafter an annuity to Peter's widow, Ruth. Peter died and John made one payment to Ruth, then stopped. Ruth sued both in her personal capacity and as administratrix of Peter's estate.
判决摘要
The House of Lords held that Ruth could not sue in her personal capacity because she was not a party to the contract (privity). However, as administratrix of Peter's estate, she could enforce the contract and obtain specific performance — requiring John to make the weekly payments. Damages would have been nominal (the estate had suffered no loss), so specific performance was the appropriate remedy.
关键引述
"The administratrix is entitled to enforce the provision of the agreement for the benefit of the widow by specific performance."
— Lord Reid
后续处理
The Contracts (Rights of Third Parties) Act 1999 now allows third parties to enforce contractual terms in certain circumstances, but Beswick remains important for understanding privity and specific performance.