What considerations have been expressed in the early jurisprudence on personal injury?

Another policy consideration expressed in the early jurisprudence is a concern with the danger of multiplicity of actions and the need for all proper parties to be before the court. For example, in Long v. Yonge (1830), 2 Sim. 369 (Ch.), a case in which some members of a partnership were seeking, on behalf of themselves and the other partners, for a dissolution of the partnership, the Vice Chancellor stated at 385: Now the rules with respect to parties are exceedingly plain and intelligible to those who will consider the principle on which they are founded. The general rule is that all parties interested in the subject of the suit, shall be parties to the record.

Although the rule in Foss v. Harbottle is most frequently encountered in the context of actions involving corporations, it has been found to be applicable in appropriate circumstances to other kinds of associations. In applying the rule to associations that are not corporations, the courts have had regard to these policy considerations: the importance of respecting consensual schemes for internal governance, and the need to avoid a multiplicity of actions and to have the proper parties before the court.