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Warner Brothers Pictures Inc v Nelson. [1936] 3 All ER 160


D entered into contract to render her exclusive services, and only perform for them. If D does not perform contract, P can extend contract. D left country and signed contract with another company. P brought injunction to restrain her from working for someone else, so she would work for them


Where a contract for personal service contains negative covenants the enforcement of which will not amount to a decree of specific performance or a decree requiring the defendant to remain idle (have other options to work in this case), the Court will enforce negative covenants by an injunction.
The Court will not grant specific performance of a contract when it is for personal service, nor will it grant an injunction when it is the basis of someone’s livelihood.

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