... to enforce a contract aiming to benefit them has been subject to considerable criticism. Lord Denning in Beswick v Beswick, Scruttons v Midlands Silicones and Smith & Snipes Hall Farm v River Douglas Catchment Bd criticised the doctrine but his attempts were unsuccessful in prompting great change. More recently, in Darlington BC v Wiltshier Northern Ltd, Lord Steyn criticised the fact that third parties were unable to enforce such contracts, calling for reform and contending that there was no doctrinal, logical or policy reason why the law should deny the right where it was the expressed intention of the parties. In the Law Commission Report, many reasons were given for the need to reform the old rule. The first reason given is that it did not protect the intentions of the contracting parties. For example, in Tweddle v Atkinson, despite the fact that the parties intended that the third party ...

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