## Facts

- Brimelow managed a chorus company and contracted with theatre proprietors to supply chorus girls for performances.
- A performers’ association set a minimum weekly wage for chorus girls, but Brimelow paid about half that amount and withheld pay during rehearsal weeks.
- The low wages and unpaid rehearsals led many chorus girls to supplement income through prostitution.
- Casson, acting for the association, pressured theatre proprietors to terminate existing contracts with Brimelow or refuse future contracts unless Brimelow paid decent wages.
- Brimelow sought an injunction to stop Casson from inducing breaches of contract and interfering with future business relations.

## Issues

1. Whether intentional interference with contractual relations—by inducing breach of existing contracts and discouraging future contracts—is prima facie actionable.
2. Whether Casson’s conduct was legally justified because it aimed to protect performers from exploitation and prostitution.

## Decision

- The court held that intentional interference with contractual rights and business relations is prima facie actionable.
- The court also held that such interference may be justified, including inducement of others not to contract.
- On the facts, Casson and the association were justified because they acted to protect their members from conditions effectively driving them into prostitution.
- The claim for an injunction was dismissed with costs.

## Legal Principles

- Intentional interference with contractual relations, including inducement of breach, is prima facie wrongful.
- Justification can defeat liability for interference with contract and may also justify inducing third parties not to contract.
- Justification may rest on protective obligations to affected persons and on strong moral grounds where the plaintiff’s practices cause serious exploitation.

## Conclusion

The court refused injunctive relief because, although Casson intentionally interfered with Brimelow’s contractual and prospective business relations, the interference was justified by the association’s protective role and the aim of preventing exploitative wages that pushed performers into prostitution.


Brimelow v. Casson, 1 Ch. 302 (Ch. Div. 1923)