Watteau v. Fenwick
High Court of England and Wales
1 Queen's Bench 346 (1892)
After transferring ownership of a tavern to brewers (defendants) while continuing to manage it under his own name, with the tavern license remaining in his name and the brewers' ownership never disclosed to outsiders, Humble -- despite the brewers privately limiting his purchasing authority to ales and mineral water -- bought cigars, Bovril, and other typical tavern supplies on credit from a supplier (plaintiff) unaware of any such restriction or of the brewers' involvement at all. When the supplier sued the brewers for payment, they argued Humble lacked authority to make those purchases and that they had never held him out as their agent.
Whether a principal is bound by an agent's unauthorized purchases made in the ordinary course of the business the agent was employed to run, where the agent did not disclose the principal's identity to the third party.