Reviewed case brief

Attorney General v Great Eastern Railway Co

(1880) 5 App Cas 473

The House of Lords established the doctrine of incidental or ancillary powers. While reaffirming the ultra vires doctrine, Lord Selborne held that it must be applied reasonably — a company has implied authority to do not only what is expressly authorised but also whatever is fairly incidental to or

ultra-viresincidental-powersancillary-powersobjects-clauseimplied-powers
Court
House of Lords
Year
1880
Subjects
Company Law
Reviewed
2026-06-30

Rule established

A company has implied power to do everything fairly incidental to or consequential upon its expressly stated objects; the doctrine of ultra vires should not be applied unreasonably to destroy the useful transactions of a company.

Facts

    Issues

      Held

        Ratio decidendi

        How to use it in an exam

        Editorial source

        (1880) 5 App Cas 473

        Educational summary only. Read the reported judgment or an authorised law report before relying on the case professionally.