Reviewed case brief

Natal Land & Colonization Co v Pauline Colliery & Development Syndicate

[1904] AC 120

The Privy Council held that a company cannot ratify a contract made on its behalf before incorporation. The doctrine of ratification in agency law requires that the principal must have been in existence at the time the agent acted; a company that did not exist at the time of contracting was never a

pre-incorporation-contractratificationprincipal-agentprivy-council
Court
Privy Council
Year
1904
Subjects
Company Law
Reviewed
2026-06-30

Rule established

A company cannot ratify a pre-incorporation contract because no principal existed at the time the contract was made; ratification requires a principal in existence at the time of the agent's act

Facts

    Issues

      Held

        Ratio decidendi

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