## Facts

- A landlord company owned a London block of flats let to individual tenants on monthly tenancies, with rent payable one month in advance.
- Under the tenancies, the landlord provided central heating and other building services; tenants complained the services were inadequate.
- A tenant, Forcey, helped form and lead a tenants’ association to press the landlord to improve performance.
- The association decided tenants should withhold rent until the landlord satisfied its service obligations and communicated this position to the landlord.
- Forcey and the association encouraged other tenants to stop paying rent when due, resulting in nonpayment to the landlord.

## Issues

1. Whether Forcey and the tenants’ association committed the tort of inducing breach of contract by persuading tenants to withhold rent due under their leases.
2. Whether the defendants had a lawful justification for inducing breach based on a shared “common interest” among tenants in securing proper services and countering unequal bargaining power.

## Decision

- The court held the defendants liable for inducing breach of contract.
- The court rejected the asserted justification defence: the tenants’ shared interest in better services did not constitute a legally sufficient “common interest” to justify procuring breaches of rent-payment obligations.
- The court granted relief for the landlord, including damages and injunctive relief restraining further inducement of rent nonpayment.

## Legal Principles

- A defendant commits the tort of inducing breach of contract by knowingly and intentionally procuring a third party’s breach of a valid contract with the claimant, causing loss, unless a lawful justification applies.
- “Justification” in inducing-breach claims is construed narrowly; a general shared economic interest (such as collective pressure for improved contractual performance) is not, without more, a lawful justification to interfere with contractual rights.
- Organizing collective nonperformance to coerce a contracting party, where it intentionally targets others’ contractual duties (here, payment of rent), can found tort liability in the absence of a recognized legal right, privilege, or statutory immunity.

## Conclusion

The court imposed liability on tenant organizers who intentionally procured other tenants’ rent-payment breaches, holding that collective rent withholding aimed at improving services was not legally justified by a asserted common interest among tenants.


Camden Nominees, Ltd. v. Forcey, [1940] Ch. 352 (Ch. 1940)