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Can a person for whose benefit a contract is made, but who is not himself the promisee and who did not give any consideration, maintain any form of action against the promisor for breach of contract? Does society recognize that he has any "rights" and enforce them at his request? In a previous artic1e/ these questions were unhesitatingly answered in the affirmative, recognizing, however, that there was a good deal of confusion in the law, and that in certain jurisdictions the third person's rights were not recognized in all cases. Among these jurisdictions were England, Massachusetts, Michigan, and Connecticut.

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