Land Law of House of Lords in Rhone v Stephens Critically assess the decision of the House of Lords in Rhone v Stephens [1994] 2 A.C. 310, with particular reference to the following statement:
‘Few would dissent from the view that in appropriate circumstances positive covenants should be capable of enforcement against successors in title to the original covenantor; that enforcement should be through direct means rather than through indirect means, which are artificial and frequently unreliable; and that the continued absence of such direct means is inconvenient and potentially unjust.’
(Nigel P Gravells, ‘Enforcement of Positive Covenants Affecting Freehold Land’ (1994) 110 LQR 346, 350.)
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