Eley v Positive Government Life Assurance Co [1876]

Companies’
articles stated Mr E shall be solicitor and shall not be removed except for
misconduct.
Mr
E himself had drafted articles.
Mr
E became shareholder soon after incorporation.
When
company used other solicitor, Mr E sued for breach of contract.
Court
of Appeal held articles did not create contract between company and Mr E.
Article
is covenant between parties that they will employ plaintiff, but plaintiff is
not party to it.