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March 15, 2006

Watteau v. Fenwick: The Victoria Inn

Victoria_inn_1 Victoria_inn_2_1 Probably no agency law case is more famous than Watteau v. Fenwick, [1893] 1 Q.B. 346, the classic case of undisclosed principals and inherent authority.  In the case, one Humble, said to be the owner of the "Victoria Hotel" in Stockton-upon-Tees, England, sold his business to a firm of brewers, who employed him to continue operating under his own name, keeping their ownership a secret.  The issue in the case has been recorded for posterity as an illustration in the Restatement (2d) of Agency:

P buys A's tavern and hires him as manager, instructing him not to buy cigars for the tavern.  A orders cigars for the tavern anyway from TP, who believes A to be the owner.  Must P honor the agreement?

The answer, said the Cout of Queen's Bench, is yes.  The brewers are stuck with the bill even though their agent violated his duties.

Victoria_inn_5 But the decision's reporter got some of the facts wrong.  There was a Victoria Hotel in Stockton, but Humble didn't own it.  Instead, he owned a less pretentious place called the Victoria Inn across the river in South Stockton -- a community whose name was subsequently changed to Thornaby.  According to local historian Jacky Quarmby, census records in 1881 show that the Victoria Inn, 8 New Street, was owned and occupied by William Humble, "licensed victualler," and his family.  Humble, a native of West Harltepool in Durham, was 37.  He lived with his wife Elizabeth (age 36), his three children, Mary Jane (14), Eliza Ann (12), and William (10), along with a 16-year-old serving girl.

The Victoria Inn was part of a lively area known as the Five Lamps district of Thornaby, after a famous Victorian-era lamppost.  There are good, but coyprighted photographs of the district, looking much as it did in 1893, here.  The Inn was close to the rail station and theTown Hall.  Here is a map of the Inn's location.

Victoria_inn_3 Victoria_inn_4_1 The Victoria Inn and the Five Lamps district survived into the 1960s, when urban renewal hit the town and the Victorian row houses and pubs gave way to shabby light industry.  (See photograph medium right, above.)  Only one of the myriad pubs in the district survives today, the Market Inn, shown at left.  At right is the Town Hall.

Top left and right:  The site of the Victoria Inn as it is today.  All photographs are copyright 2006 by Jacky Quarmby.  Permission is granted for all noncommercial educational use.

[Frank Snyder]

March 15, 2006 | Permalink

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