(c) Masterman v. Lewin, 2 Phil. 189. {d) Bignold v. Audland, 11 Sim. ^3.
ENFORCEMENT OF CLAIMS. 221

seal, will be assumpsit; when it is so, covenant; or debt, when the sum
to be recovered is liquidated, (e)

11. When the company is incorporated either by Koyal Charter or
Act of Parliament, the policy will be under their common seal, and the
action must be brought against the corporation as such; in which case it
must appear by attorney made uuder the common seal, and execution
can be levied upon the partnership property alone.
12. When the policy is issued by a company established prior to the
Joint Stock Companies Kegistration Act, the action may be brought
against the directors signing the policy, as if upon a covenant or under-
taking by them.
Thus in Bawden v. Howell, (/) when it was objected that all the mem-
bers of a loan society should have been joined as plaintiflFs, to two of whom
a promissory note had been given on behalf of the society, it was held
that such joinder was unnecessary, and in giving judgment, Maule, J.
