Rhone v Stephens [1994]

Lord Templeman –
Equity will enforce negative covenants against
freehold land but has no power to enforce positive covenants against successors
in title of land.
Nor will House of Lords overrule common law rule.
To enforce a positive covenant would be to enforce a personal
obligation against a person who has not covenanted.
To enforce a negative covenant is only to treat the
land as subject to a restriction.