Court case[1937] 1 KB 209

The film actress Bette Davis (Mrs Nelson) was under an exclusive contract with Warner Bros which bound her, for its term, to render her services only to them and not to act for any other film producer or in any other occupation without their consent. Dissatisfied, she came to England and agreed to make a film for another producer. Warner Bros sued in England for an injunction to restrain her from acting for others during the term.

Branson J granted the injunction, following Lumley v. Wagner, but limited it: it restrained her only from acting for other film or stage producers, not from earning her living in other ways, and only for the remaining term of the contract (and in any event for not more than three years) and within the court's jurisdiction. So limited, the order did not compel her to perform for Warner Bros; she remained free to do other work, even if less lucrative, and the court was merely preventing a breach of her express negative promise.