ABSTRACT
That it is necessary to protect a proprietary interest, for example, the trade secrets of a works manager in Foster v Suggett (1918); the trade connections of a solicitor’s managing clerk in Fitch v Dewes (1921). A restraint merely to prevent competition will not be enforced. In Eastham v Newcastle United FC (1964), the court accepted that the proper organisation of football was a valid matter for clubs to protect, but found the ‘retain and transfer system’ unreasonable.
