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21 Sales Resume Examples That Landed Jobs in 2024

• Sales Resume
• Sales Resumes by Experience
• Sales Resumes by Role

Writing Your Sales Resume

Sales are the lifeblood of any growing company. Without sales, companies grow stagnant—or worse, fail. But with a good sales department, a company can truly thrive.

You know how to care for customers, present solutions to problems, and adapt to any situation. Unfortunately, getting a new sales job involves more than just a short resignation letter at your current job and being stellar at what you do.

You shouldn’t have to create an effective resume or write a sales cover letter alone, which is why we’ve analyzed hundreds of professional resumes and created 21 sales resume examples just for you. These examples have helped salespeople get hired by companies like Google and Facebook , and they’re here for you to achieve the next role of your dreams in 2024.

Sales Resume Example

or download as PDF

Why this resume works

• Whether your most significant impact was in total sales, conversion rate, retention rate, or lead generation performance, it doesn’t matter—numbers speak louder than words, so include them whenever you can!

Sales Assistant Resume

• Find a way to include metrics to really sell your skills!
• Don’t just say you used a certain skill; demonstrate how you used that skill. For example, did you use your organization skills to stock many items? 
• Pack your resume objective with proactive language that shows your eagerness for growth and improvement. If you’re looking for a career-building role, then say exactly that!

Entry-Level Sales Representative Resume

• Sales is a people management game. If you have charm and patience, that’s much more valuable in the eyes of the hiring manager than an impressive educational background.
• You can also include a  resume objective  to mention some of your accomplishments and skills right off the bat; if you choose to do so, make sure you tailor it for every job to which you apply.
• If your education is your strongest area, include your minor, GPA, and any relevant courses you’ve taken.
• If you’ve worked on several projects, make room to include them on your resume in place of work experience.

Experienced Sales Associate Resume

• Your true competence as a sales associate shines through the most when you mention how you effectively calmed angry customers and offered practical, compassionate solutions.
• If you’re not overly familiar with a skill, leave it out—honesty is the best policy, and many skills are easy to learn on the job.

Experienced Retail Sales Associate Resume Example

• If you don’t have past retail experience, don’t fret; use the positions you have to highlight transferable skills, like time management, customer service, and problem-solving.
• Instead of just listing responsibilities, include any achievements, too. Were you a top salesperson in your store? Did you increase your customer review rating? Did you cross-sell effectively and increase revenue? All of these are great examples to include!

Senior Sales Analyst Resume

• Include a  resume summary  (also called a career summary) if you can boast 10+ years of field experience. Make it a concise, customized snapshot of yourself by including your specializations, defining expertise, and mentioning the target business by name.
• You can include the number of employees you manage or mentor, the rate at which you’ve increased revenue, the rate at which employees have hit sales targets during your tenure, the number of departments you collaborate with, the number of monthly presentations you give, and any other metrics that showcase how you’ve improved company performance.

VP of Sales Resume

• A good example is the training program you initiated, which boosted team morale and overall productivity by 38 percent.

Pharmaceutical Sales Resume

• Did you help expand market share? Did you leverage technology to help close more sales deals? Add all that in and sit back as your past success elevates your candidacy to the top of the shortlisted applicants.

Insurance Sales Resume

• Highlight how you’ve tapped InsurGrid, NowCerts, ClearSlide, etc. to improve customer service, and attract and retain customers. Also, back your competencies with realistic figures that underscore your impact.

Tech Sales Resume

• Be bold, like Asher, in showing off to what extent your skills and knowledge contributed to the company’s sales department.

Sales Representative Resume

• Make sure every section of your sales representative resume is easy to read and distinguish by either capitalizing them, bolding them, or using a colored font.
• Any mistakes will be easy to see and will hurt your chances of getting an interview. So, always  check your resume  before you submit it!

Sales Manager Resume

• Focus your work experience on your sales achievements and management expertise. Even if you have no sales management experience, you can still show off your sales skills and leadership qualities wherever it was that you worked. 
• When you can, include metrics that quantify your success. Saying you conducted meetings is one thing, but conducting meetings that resulted in a 14% increase in leads is another.

Digital Sales Representative Resume

• A  good resume template  will help you structure your content effectively, but be aware of spacing—even a good resume template won’t help if your text is too tiny to read or spreads into the margins.
• If you’re stumped on what numbers to include, consider these options: response time, the number of active accounts, size of the average account, churn dollars, team size, ROI, social media post engagement, the number of products you know, and how many awards you’ve won.

Sales Strategist Resume

• There are many  good resume examples  if you know where to look, and they can help you break out of your writer’s block funk. Take a look and get some inspiration!
• Moreover, you can ask some co-workers to help you, too! They can help you decide what metrics to include and how to sound confident but not arrogant.
• For example, if you’re a senior-level employee, you don’t need to include much in your education section, but you should include more work experience bullet points.
• However, if you’re new to the field, you can include your GPA and educational awards while minimizing your work experience in favor of projects.

Sales Consultant Resume

• A strong network on LinkedIn indicates that you’re good at building professional relationships, which is an essential element of sales.
• If you haven’t updated your LinkedIn in a while, make sure you do that as soon as possible.
• For example, you can talk about unveiling events for clients, creating working relationships, and building up networks. These details demonstrate that strong customer rapport is, in fact, a skill you possess.

Sales Engineer Resume

• For example, if the job you’re applying to emphasizes the importance of using CRM software or building long-lasting relationships with customers, emphasize these skills in your skills section. 
• Focus on including hard skills similar to the ones used in the  sales job description .
• If you’re just starting your career in sales engineering OR transitioning to a different type of role, include an objective.
• If none of the above applies, leave it out in favor of more work experience.

Director Of Sales Resume

• Don’t forget to list accomplishments related to leading people and building customer relationships, starting by recording how many customers you helped or how many people you led. Then look for percentages relating to KPIs from there.
• If you’re stuck on what to include in your  resume skills section , go back to the  sales job description  and see what soft skills they require, whether explicitly stated or implied.

Outside Sales Representative Resume

• Good examples include the number of new accounts you opened, conversion rate, retention rate, lead generation performance, and overall growth.
• Sales revenue is the main statistic related to every sales position, but make sure you venture outside the box to include other metrics, too.
• You’d be amazed at what tiny typos and punctuation errors can slip through without your noticing, and employers will appreciate your attention to detail!
• Run your resume through a  resume checker  or spellcheck system, then proofread it again with your own eyes.

Software Sales Representative Resume

• For example, did you exceed your sales quotes, and if so, how many times? How much did you increase profits for the company? 
• Provide details that prove you can boost numbers at the next company you’ll work for!
• If you can, shoot for half and half between technical and soft skills, but if you’re an entry-level candidate, it’s okay to have more soft skills.
• As a software sales rep, you should include the programming languages you know, plus soft skills like “negotiation” and “interpersonal communication.”

Fragrance Sales Associate Resume

• For a successful career in sales, you’ll want your communication and persuasion skills to shine just as brightly as your technical knowledge. Be sure you include some of both in your fragrance sales associate resume .

Sales Development Representative Resume

• Sales are all about the numbers. When you’ve brought about tangible positive results at your past workplaces, it speaks to how effective you are as a salesperson and should be touted in your sales development representative resume .

Related resume guides

• Sales Associate
• Sales Representative
• Sales Manager

Proper formatting ensures your resume is readable, logical, and complete. If you neglect the formatting, you risk potential employers not taking your application seriously (or not even seeing your resume). When it comes to formatting, remember the following: 

• Choose one of three resume format options 
• Draw attention to your resume header 
• Make your sales resume accessible for the ATS and employers

Overall resume format options

Hiring managers’ preferences tend to change over time, but for 2024, it’s clear that three  resume formats  are the most popular:

• Reverse-chronological format:  This format emphasizes your most recent experience by placing work experience toward the top of your resume. Ordering your experience this way highlights career growth and development.
• Functional format:  A functional format stresses skills over work experience. This type of format may be appealing if you have little work experience or if there are gaps in your employment. 
• Combination/hybrid format:  This type combines reverse-chronological and functional formatting, placing equal weight on job history  and  skills, but it can be hard to read because of this.

Though all three types are popular,  hiring managers prefer   the reverse-chronological format . It’s easy to read, underscores career growth, and looks honest regarding your job experience. 

Draw attention to your resume header

Presenting your contact information may seem unimportant. However, this is the most important information in your resume; without it, how can you expect hiring managers to tell you “you’re hired?” Don’t make the mistake of underestimating the importance of an accurate and beautiful resume header.

Start by aligning your header either to the left or center. Then write your name in a large font size so you can see it from far away.

Right below your name, include your job title in a slightly smaller font. Then if you like, you can tastefully add some color to show your personality. (We love cobalt blue and buttercup yellow, but we’re a bit biased.)

Underneath your name and title, list your contact information. Keep the text the same font size as the body of your resume, and consider including a border (with or without color) to make it pop. This section should include:

• Your email (make sure it’s professional and not something like “[email protected]”)
• Phone number (with an area code)
• City & State (optional but recommended)
• Professional links to portfolios or sites like LinkedIn (optional but recommended)

Make your sales resume accessible to the ATS and employers

Once you upload your resume to an online job application, it won’t go straight to a hiring manager’s desk. Instead, it will go through the ATS, or Applicant Tracking System software.

This system uses keywords in your resume to determine your likelihood of being a good fit for a particular sales job. If you don’t pass the ATS scan, it’s doubtful you’ll get an interview.

To get past the software and reach human eyes, pay attention to:

• Margins:  Use standard half-inch or one-inch margins all around.
• Fonts:  Use professional, easy-to-read fonts like Times New Roman, Arial, or Georgia. 
• Font sizes:  The body of your resume should be the smallest font at around 12-point, your job title should be 20-point font, and your name should be approximately 24-point font.
• Header names:  Instead of adjusting font size for section headers, try bolding them or using all caps. 
• Skills:  You can list them in a horizontal or vertical list; we recommend using bullet points in a vertical list unless you lack space. 
• Logical order:  As we suggested earlier, we recommend a reverse-chronological format since it’s easy for the ATS to scan. 
• One page:  You must fill one page  exactly . You can slightly adjust fonts, font sizes (just a touch), vertical spacing, and margins to hit this target.

If you’re struggling to  build your resume  with enough content and proper formatting, remember this: the most important thing is to  ensure your resume is read . If you have to cut content to keep your formatting easy to read, do it.

Do you really need an objective or summary?

Contrary to sources floating around the internet, there  is  a difference between a  resume objective  and a  resume summary . Both are short paragraphs written explicitly for every application you submit, but there are a few key differences between them. 

An  objective  identifies why you’d like to work for the company under the specific job title for which you’re applying. A  summary  highlights the skills you possess and what achievements you’ve earned within your past positions.

Objectives and summaries are strictly optional, but there are a few instances where adding one would help.

• Consider including an objective if you’re seeking an entry-level role or are transitioning careers.
• Consider using a summary best suited if you have 10+ years of sales experience.

Customized resume objective:  Seasoned floor salesperson with 4+ years of experience hitting sales 7% above targets. Seeking a position with Neiman Marcus, where my specialization in high-end retail will continue the tradition of upholding the highest standard of luxury retail experiences for clientele. 

• This objective is specific to the job and includes a customized job title, quantified metrics, specific skill sets, and the company name. It adds real value and will impress any hiring manager.

Poor summary statement:  Dedicated applicant with experience in sales and marketing looking for a sales associate role to improve customer service skills. 

• This statement is anything but specific, and it could be on any number of sales resumes. More than just that, it doesn’t highlight any skills or qualifications beyond dedication. Major yikes.

Customized summary statement:  Results-driven sales associate with 13+ years of experience developing rapport and good customer relations. Leveraged top marketing strategies to yield results, performing in the top 5% of sales associates at all workplaces for over a decade. From informing customers about purchases to designing trending storefront decor, I am confident that my proven excellence in results-driven sales strategies would positively impact the movement of products at Decor 101. 

• This summary statement is customized and unique, including specific skills and quantifiable metrics to support their claims; this candidate is a top choice for an interview.

Know what to include in your job experience section

When writing your sales resume, you may be tempted to include every job you’ve had since you were 16. Though this may be an appropriate choice if you have limited job experience, we recommend including two to four highly relevant jobs on your sales resume if you have more experience. 

Write your work experience bullet points purposefully

When you write your work experience section, remember that space is crucial. To take up less room, use bullet points to break up chunks of text. Start each bullet point with an action verb, such as “oversaw” or “championed,” to drive your value (and cut filler).

Using action verbs will also lay the foundation for using active (rather than passive) voice. For example, a passive sentence like “The store was closed by the sales team” sounds weak and boring. Active voice gives agency to the subject and shortens the statement: “The sales team closed the store.” 

Avoid personal pronouns when writing about your experience, such as “I” or “we.” Ending punctuation is up to you—just be consistent. (Avoid having periods at the end of all your bullet points except for one, for example).

Finally, keep your verb tense in the past, and make sure it’s consistent.

Good bullet points can look like any of these examples:

• Executed an outbound calling strategy to warm leads, leading to a close rate of 16%, which exceeded targets by 50%
• Implemented and expanded the use of Salesforce, saving over 18 hours of weekly manual reporting time by sales staff
• Led initiatives for prospective home buyers to improve brand awareness and increase inbound customer interest, resulting in a $275,000+ increase in incremental revenue

These bullet points are successful because they start with action words, maintain an active voice, avoid personal pronouns, and are consistent with punctuation and tenses. 

Getting these things correct is tricky, but you can return to this guide anytime to review these tips!

Use numbers to your advantage

You may have noticed that all the bullet point examples we included contain numbers. Metrics are essential for any resume, but especially your sales resume. Words tell hiring managers you’re good at your job, but numbers show undeniable value. Include quantified metrics within at least 50 percent of your bullet points. 

Here’s how:

• Performance relative to targets:  Have you ever or do you consistently outperform sales targets? By what percentage do you exceed targets on average? 
• Improvements per customer:  Do your customers have higher purchase totals than others? Are they making more repeat purchases than customers helped by other sales associates? What’s your close rate? 
• Efficiency standards:  How many customers do you help on average, per hour, day, or week? How long does it typically take you to make a sale? How many seconds does it take you to greet customers? 
• Customer relations:  How many customers have reviewed you positively on customer surveys? Have any customers mentioned you by name in positive reviews?

It helps to see these tips in practice, so here are some examples: 

• Improved the shopper-to-customer conversion rate of the store by 6% by prioritizing immediate customer service of inbound customers
• Responded to customer questions with a detailed understanding of products, resulting in a customer satisfaction rating of 96%
• Recognized as a Top 5% Salesperson in the most heavily trafficked Kay’s store in Maine 
• Exceeded annual membership targets by 23% by encouraging a compassionate, customer-centered approach

Select appropriate sales skills for your resume

The skills section is one of the shortest sections on your resume and one of the most mysterious. Unfortunately, the ATS plays a big part in this section since it scans your resume for pre-selected keywords.

Not enough keywords? Not the right keywords? ATS wins, 1 to 0. 

We’re here to shed light on this mystery using a simple trick. When writing your skills, choose those mentioned in the  sales job description . Of course, don’t include every skill they list, but use the job description to guide your strengths.

Ideally, include a mix of both hard and soft skills for a total of six to 10 skills. Hard skills are easier to measure, so we recommend listing mostly hard skills. However, soft skills, such as “organization” and “customer service,” are critical in a sales role, so include a few that match your abilities. 

Let’s put this trick into practice! Here’s an excerpt from a sales job description: 

Seeking qualified sales associates! Our ideal candidate thrives in a fast-paced work environment and can maintain a positive, upbeat attitude with co-workers and customers under stressful situations. Must utilize standard software to track and follow up with leads. Should be charismatic, comfortable with public speaking, and have a solid ability to memorize merchandise details and answer complex customer questions. We serve a predominantly Hispanic population, so Spanish speakers, please apply! 

From this job description, we can create a list of skills that would be particularly appropriate for this job position: 

• Salesforce and HubSpot CRM
• Bilingual (Native English, Fluent Spanish) 
• Customer relations
• Interpersonal communication
• Product knowledge 
• Sales demos and pitches
• Time management 

 No matter the job you’re applying for, you’re likely to see some of these skills: 

• Cold-prospecting 
• Negotiation
• Work stream management
• Trend forecasting
• Traditional lead-generation
• Presentations 

Education, certs, interests, and hobbies

In sales, employers typically only require a high school diploma or equivalent. However, specific educational requirements will vary widely in such a large field. Some employers will seek applicants with a bachelor’s degree in business or even an MBA. 

So in your sales resume, list your highest level of education. If you have a graduate degree, you can include both it and your undergrad degree.

If you have any certifications or additional training, such as software certification for a particular type of CRM, you can include that, too, although it isn’t required.

Typically, sales professionals don’t include an optional  interests and hobbies section on their resumes , but there are a few circumstances where it may be appropriate: 

• Hobbies can demonstrate that you’re the type of person a potential customer might enjoy chatting with, which is a bonus for employers.
• Use projects, like volunteering or academic extracurriculars, in place of work experience if you’re light on jobs. 

Here’s an example of what projects could look like on your sales resume:

Tailor your sales resume to the job description

Remember to customize your resume  every time  you apply for a job. Tailoring your resume to the job description is the best way to land an interview quickly.

Start by reworking your resume objective or summary statement (if you have one). Then adjust your skills section to include skills relevant to the role. Finally, adjust your job description bullet points to include relevant qualifications. 

For instance, if a job description mentions they’re looking for a sales representative who can begin giving presentations on day one, emphasize your comfort in public speaking roles. Highlight your previous presentation experience, and perhaps de-emphasize the data analysis skillset that is less relevant to this job. 

Pro tip:  You can keep a master list of bullet points for each job title in a separate document . Write down as many skills and responsibilities as you can for every job title, and organize them based on their emphasis (time management, customer relations, data analysis, etc.). Then you can pull from this document to create fully-customized resumes quickly. 

Edit and polish your sales resume

When finished  writing your resume , it’s tempting to submit it immediately, but it’s best to take a step away first. Give your eyes and mind a rest for a day, and send your resume to trusted family and friends for review. Then you can adjust your content and  check your resume  for errors before you submit; that way, you don’t miss the little details you may have inadvertently overlooked!

Ready for the Next Step?

The first step to having an interview-ready, professional sales resume is to take the time to research and prepare. Congratulations on helping out your future self by using our guide! 

Our easy-to-use  resume builder  will allow you to build your resume from the ground up with perfect formatting, so you can save serious time and focus on your next sales job. If you’re ready to find out how your resume stacks up, use our  resume checker  to give you AI-powered suggestions to polish your resume to perfection. 

We know that wherever you get hired, you’ll be helping customers and growing revenue in no time!

Land your next job with our AI-powered, user-friendly tool.

Gut the guesswork in your job hunt. Upload your existing resume to check your score and make improvements. Build a resume with one of our eye-catching, recruiter-friendly templates.

• Work in real-time with immediate feedback and tips from our AI-powered experience. • Leverage thousands of pre-written, job-specific bullet points. • Edit your resume in-line like a Google Doc or let us walk you through each section at a time. • Enjoy peace of mind with our money-back guarantee and 5-star customer support.

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Sales Resume - Example & Writing Guide for 2024

You’re a sales rep.

You use your skills to sell products or services to customers and companies.

But when it comes to creating a convincing resume, you’re left confused.

How do you make a sales representative resume, anyway?

Surely it’s no different than a resume for any other profession, right?

Fortunately, this guide will answer all of your questions. In fact, we take you through a simple step-by-step process to creating a sales resume with a super-high conversion rate . 

• An example of a finished sales resume that works
• How to write a sales representative resume that’ll fill up your interview diary
• How to make your sales representative resume stand out [with top tips & tricks]

Before we look at the finer details, here’s a sales resume example , created with our very own online resume builder :

Looks good, right?! Follow the steps below to create a sales representative resume that get results, just like the above example.

Applying for a different job position? Feel free to check out our related resume examples here:

• Sales Associate Resume
• Marketing Executive Resume
• Marketing Resume

How to Format a Sales Representative Resume

Before you can wow the recruiter with your vast sales expertise, you need to pick the best format.

Basically, you need to make your resume easy to read.

You will also want to highlight your core strengths, which rely on choosing the correct format for your specific situation.

If you want to impress, the “ reverse-chronological ” resume format is recommended. Essentially, it puts your most recent and most notable strengths at the top, which allows the recruiter to see your value in an instant. We recommend starting with this format .

The following resume formats also get our approval:

• Functional Resume – If you’re confident about your sales skills, but lack the experience, this resume format is recommended
• Combination Resume – Combining both “Functional” and “Reverse-Chronological” formats, use this format if you’re an experienced sales representative

Once you’ve chosen your format, you need to organize your resume layout .

Use a Sales Representative Resume Template

Here’s the harsh truth –

You won’t get any sales job if your resume isn’t formatted correctly.  

It needs to be scanned by humans and robots alike. 

You could use Word, but the resume format is at risk of falling apart with a single change.

If you want to skip formatting issues, use a sales rep resume template .

What to Include in a Sales Representative Resume

The main sections in a sales representative resume are:

• Work Experience
• Contact Information

Want to go a step further? You can also add these optional sections:

• Awards & Certification

Interests & Hobbies

That sounds great, but what do we write for each of these sections? 

Read on to learn how.

Want to know more about resume sections? View our guide on What to Put on a Resume .

How to Correctly Display your Contact Information

Unlike your sales presentations, this section doesn’t require flair.

But it must be factually correct. 

One misplaced digit can completely destroy your chances of receiving a phone call.

The contact information section must include:

• Title – Align this to the job description. In this case, “Sales Representative”
• Phone Number – Check this multiple times
• Email Address – Use a professional email address ([email protected]), not your childhood email ([email protected])
• (Optional) Location – Applying for a job abroad? Mention your location and if you are open to relocate.
• Phillip Green - Sales Representative. 101-358-6095. [email protected]
• Phillip Green - Superhero Salesman. 101-358-6095. [email protected]

How to Write a Sales Representative Resume Summary or Objective

Just like a customer glancing over products on the shelf, the hiring manager will only spend just a few seconds looking at each resume.

Although worrying, this fact highlights the importance of a resume that makes a big impact within the first few sentences.

But how can you do this?

Well, by using a resume summary or objective.

These are short, snappy paragraphs that sit at the top of your resume, just under your contact information.

But how do the two differ and which one should you pick?

A resume summary is a 2-4 sentence summary of your professional experiences and achievements.

• Experienced sales representative with a strong background in boosting sales for a diverse clientele. Seeking to leverage solid sales skills and extensive technology knowledge to be the senior sales rep for Random Technology Store. Notable achievements include achieving over $250,000 in sales for every fiscal quarter, maintaining relationships with 15+ large contractor companies, and increasing gross profit by 42% from 2017 to 2019.

A resume objective is a 2-4 sentence snapshot of what you want to achieve professionally.

• Motivated individual with passion and vast knowledge of gaming technology, seeking to become the new sales representative for Random Technology Store. Experience includes working as a sales associate to help customers find products, answer stock questions, and promote store awards program.

So, which one is best, summary or objective?

Whether you choose a summary or objective will depend on your experience as a sales representative. Those with a strong history on the sales floor should go with a resume summar y, whereas those who have sales skills, but lack the industry experience, should choose an objective.  

• As a sales representative, you know that benefits sell. As such, make it clear how your experiences and skills will HELP the company.

How to Make Your Sales Work Experience Stand Out

The recruiter is looking for someone that can sell.

And when we say sell, we mean SELL .

The easiest way to prove that you can sell ice to the Eskimos is with your work experience .

Here’s the best way to structure your work experience section:

• Position Name/Title
• Company Name
• Responsibilities & Achievements

Sales Representative

WeSellCars Ltd.

03/2015 - 06/2020

• Achieved over $250,000 in sales for every fiscal quarter 
• Maintained relationships with 15+ large contractor companies
• Increased gross profit by 42% from 2017 to 2019
• Lead and presented all company product promotions

To really sell your value, you should focus on your best achievements, rather than your daily tasks.

Instead of saying:

“Sales lead”

“Achieved over $250,000 in sales for every fiscal quarter.”

Simply put, the first statement is way too vague. It shows you were in charge of sales, but it doesn’t say whether you actually sold anything or not. 

The second statement shows that you managed to sell A LOT , and consistently too. Hard numbers that prove your skills – can’t argue with that!

What if You Don’t Have Work Experience?

Maybe you’re a graduate looking for your first sales job?

Or maybe, you have experience in sales-related jobs, but never as a sales representative?

Don’t worry –

Simply list all previous job responsibilities that are most relevant to the job description.

Even though you haven’t held an official sales representative job title , it doesn’t mean you don’t have relevant experience or skills.

Are you recent graduate? Make sure to check out our student resume guide !

Use Action Words to Make Your Sales Resume POP!

…are all common words that the recruiter sees time and time again.

However, you want to separate your resume from the competition, which means using power words to make your achievements stand out:

• Conceptualized
• Spearheaded

How to Correctly List your Education

Next, it’s time to talk about your education.

Depending on the job you apply for, you may require a degree or high school diploma. 

Those with impressive sales achievements may not need to impress with their education at all.

There’s nothing too complicated with this section, just list the basics in the following format:

• Degree Type & Major
• University Name
• Years Studied
• GPA, Honours and relevant courses.

B.A. in Strategies in Sales Management

University of Michigan

2012 - 2016

• Relevant Courses: Sales Forecasting & Budgeting, Developing Strategic Relationships with Major Customers, Managing Sales-Related Change, Developing and Using Customer Insight

We understand that you may have further questions. If so, here are the answers to some of the most frequent questions that we get:

What if I have not yet finished my studies?

• Regardless of whether you’re a sales graduate or still studying, you should still mention every year of education to date

Should I include my high school education?

• Just include your highest form of education, which will likely be your high school education if you didn’t go to college 

What is more important, my education or experience?

• In the sales field, your experiences are the most important, so those go first.

Be sure to check out our guide on how to list education on a resume .

Top 15 Skills for a Sales Resume

A top sales representative is able to show their talents through the number of sales they convert.

You won’t even get to that stage if don’t include the correct skills on your resume.

Here are some of the most common sales skills that the recruiter will be looking for:

• Product Knowledge
• Rapport Building
• Time Management
• Product Presentation
• Contract Negotiation
• Closing Sales
• Prospecting
• Public Speaking
• Problem Solving
• Conflict Resolution

Here’s a more comprehensive list of 100+ must-have skills this year .

What Else Can You Include?

We’ve now covered every essential resume section .

But ask yourself one question –

Have you done enough to make the sale ?

You need your resume to stand out !

Adding additional sections can really round you out as a candidate.

Awards & Certifications

Have you won salesperson of the month?

Have you completed any courses to improve your sales skills?

If you said yes to any of the above, make sure to mention them in your resume!

Here’s an example:

Awards & Certificates

• “The Art of Sales” - Coursera Certificate
• “Public Speaking Masterclass” - MadeUpUniversity

As a sales representative, you will be communicating with a diverse clientele. 

As such, it can be useful to know other languages.

Either way, being able to speak a second language is always an impressive skill to a hiring manager, so feel free to add a language section if you have space.

Rank the languages by proficiency:

• Intermediate

This section simply requires a sentence about what you like to do when you aren’t working. 

Doing this allows the hiring manager to see what kind of person you are. 

This section also adds a more personal touch to your resume.

Here’s which hobbies & interests you may want to mention.

Include a Cover Letter with Your Resume

Want to increase your chances of getting the interview call?

Attach a cover letter with your resume.

Cover letters are still an important part of the hiring process.

You see, a cover letter is a specific and personal piece of content. 

Unlike an applicant that sends a generic resume to every company, a cover letter shows the hiring manager that you care about working for their company.

Here’s the winning formula:

You should complete the following sections:

Personal Contact Information

Your full name, profession, email, phone number, location.

Hiring Manager’s Contact Information

Full name, position, location, email

Opening Paragraph

It’s no secret that recruiters skim through applications. As such, your opening paragraph must be immensely powerful. Use concise language to mention:

• The position you’re applying for
• Your experience summary and best achievement to date

Once you’ve sparked the reader’s interest, you can get deeper into the following specifics:

• Why you chose this specific company
• What you know about the company
• How are your top skills relevant for the job
• Which similar industries or positions have you worked in before

Closing Paragraph

• Don’t just end the conversation abruptly, you should:
• Conclude the points made in the body paragraph
• Thank the hiring manager for the opportunity
• Finish with a call to action. This is a good way to start a conversation. A simple “At your earliest opportunity, I’d love to discuss more about how I can help company X” will work

Formal Salutations

End the letter in a professional manner. Something like, “ Kind regards ” or “ Sincerely. ”

For more inspiration, read our step-by-step guide on how to write a cover letter .

Key Takeaways

If you combined your sales skills with the advice above, you should have successfully convinced the recruiter to give you an interview. 

Before leaving, let’s sum it all up:

• Format your sales resume correctly. Prioritize the reverse-chronological format, and then follow the best practices on content layout
• Start your resume with a summary or objective to hook the recruiter
• Highlight your top sales achievements, rather than your daily duties
• Use your sales skills to write a convincing cover letter

Suggested Reading:

• The One-Page Resume of Richard Branson
• What Is Your Greatest Accomplishment? [3 Proven Answers]
• 101 Career Paths for Every Personality [2024 Guide]

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• • Exceeded sales target standards by an average of 44% in an ultra-competitive ERP software niche during the first year
• • Developed three previously unused customer acquisition channels: social, email, inbound sales to grow potential customer database by 450%
• • Consolidated the clients territory and grew the sales in new clients by 35% of the sales accomplished
• • Designed & developed website for online editor http://3dhomeonline.com/editor
• • Achieved 100% user approval rating of world-class application redesign
• • Responsibility for establishing a lean, user-centered design process and culture across a digital team of 6
• • Worked on a team of 6 to build an educational app that teaches electrical engineering concepts to kids
• • Assigned as one out of 10 key advising representative for top tier merchants for a new product line
• • Facilitated $600,000 worth of new business annually after implementing new direct sales strategy
• • Personally responsible for 75 and 120 new accounts in 2011 and 2012 years through cold calling
• • Nurtured, managed, and grew a $2.1 million customer database as an account manager over three years

17 Sales Resume Examples & Guide for 2024

Customize this resume with ease using our seamless online resume builder.

All resume examples in this guide

Entry-Level Salesperson

Sales Representative

Sales Manager

Sales Associate

Software Sales

Solar Sales

Jewelry Sales

Door To Door Sales

Enterprise Sales

Executive Sales

Inside Sales

Outside Sales

Phone Sales

Luxury Sales

Furniture Sales

Construction Sales

Director of Sales

Resume guide.

Resume Outline

Resume Layout

Resume Header

Objective/Summary on Resume

Experience Section

Education Section

Sales Skills

Certifications on Resume

Other Resume Sections

Sales Cover Letter

Key Takeaways

By Experience

The best sales resumes sell you as the best candidate for the job.

You need to show you have the drive, skills, and experience to succeed in the role you’re after.

The most efficient way is to demonstrate your potential impact to the company’s bottom line - and you need to make sure that’s all wrapped up in an engaging and memorable sales resume format.

This may sound like a tall order, but we’ll help you get there - with expert advice, plenty of samples and templates, and even a big data analysis to help you get the sales job you deserve.

“A compelling and engaging story is an amazing tool not only for advertising, but also for closing the sale.”

Solomon Thimothy, OneIMS in Nine Simple Tips To Optimize Your Sales Pitch For Conversions on Forbes.com

In this guide, you’ll learn how to create a sales resume:

✔ Choose the best sales resume template for your experience level ✔ Include technical and soft skills that reflect the job description ✔ The importance of crafting a sales resume summary or objective ✔ Create a sales resume with no experience that can still showcase relevant skills ✔ The right and wrong way to put education on a sales resume based on your experience level

How to create the best sales resume outline

Every sales job gets hundreds of resumes, and the hiring manager can only spend a few hours going through them all.

To get noticed in this pile of resumes, you need to rely on a resume that ticks off a bunch of boxes.

First, it needs to be visually attractive and memorable. This ensures that the hiring manager will stop leafing through that pile of candidates when they see your sales resume.

But the sales resume template needs to do more than that. It should not only attract their attention, but also make content easier to grasp.

In order to make this happen, you should start by mapping out the important sections you need for your sales resume.

Here’s the most common content in a sales resume outline:

• Sales Experience
• Soft Skills
• Technical skills
• Achievements

Adding your sales experience in reverse-chronological order alone won’t cut it. You need to use special resume sections that make your key achievements stand out.

Finally, your resume outline and template should naturally guide you to demonstrate your impact. Keep in mind, you shouldn’t just list sales responsibilities from past positions, mentioning the results of your efforts is going to have a far greater effect.

Plenty of those other hundreds of salespeople you’re competing with have had similar responsibilities. Only the best salespeople can show business impact.

Choose the sales resume layout that will work best

Before someone reads a single line of text from your resume, they’ll notice the layout and template.

So choose a template that sends the right message for you.

• Basic layout - this single column template is ideal for someone looking to get hired as an entry level salesperson. If you don’t have a ton of experience for your resume, this presents that, so it’s incredibly easy to read and doesn’t look light.
• Professional layout - use this template if you’re applying for a big corporation like Microsoft, or any other publicly traded company. Sales is all about making the right impression at the right time, presentation is paramount, so especially in those companies it’s good to use a professional sales resume layout.
• Simple layout - applying to a company that you don’t know much and you don’t want to risk getting rejected? Then this layout can work best for you. It makes it easy to show your sales experience and skills without catching the hiring manager off guard with a unique layout.
• Creative layout - Have you made a sales career from being unique or one of a kind? Or you’re applying for a sales or business development in a young startup. Then you should consider using something more colorful with more personal sections to show them how you stand out from the other saleswomen or salesmen.

Here’s what to consider when choosing the perfect sales resume layout:

• Be sure it presents your relevant sales qualifications clearly
• It should place your most important sales information at the top
• It should be easy to read and catch your eye
• If you have sales awards and achievements, be sure to highlight them in their own section
• It should work with ATS (Applicant Tracking Systems)
• Be sure to send it as a PDF

Like a great sales presentation, your sales resume layout should have a start, middle and end that is clear and has a great flow.  If you can do this, then you’re already well along the way of closing your new sales position!

If you feel that you don’t have the level of sales experience that the company is looking for, then you can still consider using a creative layout. It’s a great way to promote your non-traditional sales experience and might help you get noticed and invited for an interview.

Let your sales resume header make a great introduction

Remember, competition is what sales is all about.

You’re always trying to get that sale before the competition does.

First impressions matter, no matter what you’re selling. Even yourself!

You don’t want your name, address and contact info to be the reason you’re not in the running, right?

A lot of salespeople don’t realize the importance of their sales resume header, so let’s talk about what you need.

A great resume header should include:

• Resume Title - include your top sales experience, with your sales career goals and add something unique about yourself and any sales awards you’ve received.
• Picture - It’s very common to include a photo for a sales or business development resume. Make sure it’s professional, as it will go a long way to give the HR department a good impression of you. You should always check your local rules about including photos on resumes, as in some regions and with some employers it isn’t allowed.
• LinkedIn - It’s hard to be a great salesperson today with the networking power of LinkedIn. You likely have an enormous network of great contacts there, so why not let the hiring manager see how connected you are!
• Email - You should always include your email. Corporate HR departments regularly reach out via email for interview details.
• Certifications - You might have a Certified Sales Person (CSP) certification. It is essential that you include this after your name in your sales resume header. It may be the difference maker between you and the others that get selected for the sales position.

So, if you put yourself in the place of the sales manager reviewing your sales resume you can see where the wrong example above is lacking.

They’re going through hundreds of resumes that just have a name and basic title.

The resume header is the first impression your resume makes, so don’t leave them wanting more!

Unless you have a social media account, other than LinkedIn, that is devoted to your profession or field of work it isn’t a good idea to include social media on a sales resume as it has no relevance to the position.

How to write a sales resume objective or summary

One often overlooked element of a resume is the objective.

The idea is to quickly give the reader some information about who you are and what your goal is. This enhances the rest of the resume by giving it valuable context.

So what’s the best way to go about this?

A good sales resume objective will highlight your desire to create Win-Win-Win situations that benefit your customer, your employer, and you as a salesperson.

A resume objective should be highly tailored to the sales job description. Look for keywords and make sure you clearly show how your experience overlaps with the needs of your potential employer.

Wow, when you see the two sales resume objectives, it’s obvious which isn’t going to make the sale!

The first example packs a powerful sales pitch in just 19 words!

It instantly lets the hiring manager know:

• You’re certified
• You’ve won sales awards
• Have over 10 years of sales experience
• Have worked on major global sales
• Your experienced in software and technology sales

So you can see how much power the sales resume objective has in getting you noticed. Right?

A good sales resume objective is actually serving a dual purpose - it shows what you have to offer as a candidate, but it also demonstrates your ability to align someone’s requirements with your proposition.

This is a key skill for a sales associate.

How should you include sales experience on your resume?

sales resume experience is all about hard numbers.

Make sure you clearly demonstrate what your impact was in past positions.

Focusing on this by citing hard numbers is far more effective than simply listing your responsibilities for each role. Have a look below at some great and not so great examples.

Resume Experience Examples

• • Created and managed a new 10-people sales department that surpassed the top individual quota KPI’s for 3 years in a row
• • Led a team of sales executives in a sales campaign that resulted in increased sales of $500k and the company exceeding its annual sales targets by 25%
• • Received the 2017 Salesperson of the Year award. Selected from a list of 14 candidates.

First, you need to make sure your job title is as clear and impressive as you can. This isn’t the time to be humble!

While it’s not always possible to provide exact metrics of how you impacted some areas, you can see how this experience example mentions specifics whenever possible. It also highlights key areas where they excelled at managing teams and exceeding goals.

• • Handled designated sales territory, regularly meeting sales goals
• • Attended weekly national sales status calls
• • Part of a team of 15 sales managers

Ok, this example doesn’t say anything other than you had a sales job and did the tasks you were asked to do. You can already see this resume going on the “no” pile can’t you?

Don’t simply list tasks. Doing this demonstrates a lack of motivation and that go-getter mindset that every sales position is looking for.

Additionally, make sure your resume tells a compelling story - this is where a full work history may be the right solution. It should represent a clear path, showing your progression over time.

But, what if your past positions don’t include “sales” in the title? Simply use the description and responsibilities outline to show any links to sales or its key skills - communication, organizational, and proactivity.

Finally, compare your experience section with the details listed in the job description for your sales position. This will remind you of anything you might’ve missed during the writing session and will give you hints on what achievements you’ll want to highlight further in your resume.

What if you need to create an entry level sales resume experience section?

So how can you create a sales resume experience section when you don’t have any?

Don’t worry, we’re going to show you how to do that now.

Maybe you just recently graduated from school? Or are making a change into a sales career?

You may think you don’t have the sales experience that is needed for a great sales resume, but in just a few moments you’re going to realize that you’ve got more sales experience than you think!

While you may not have been the VP of Sales for North America, you’ve most likely worked in an environment that required the necessary sales skills to make a great salesman or saleswoman. This experience could come from an internship, a side project, an organization you volunteer for, etc.

Here’s what you should do:

• Start by identifying the kinds of skills and experiences you think will be relevant for the sales job you’re applying for. For example, the posting may be looking for someone experienced in customer service or account management.
• Now, look back at your previous experiences to see what you may have done which could demonstrate that. In this example, maybe you worked in retail or another customer service job where you needed to listen to the customers needs and make sure they were always happy.
• Once you’ve got the right experience, emphasize it using the same language the job description did.

With these techniques, even if you’ve never had a job as a salesperson, you can still show you’re qualified for your first position.

Of course, if you’re creating an entry level sales resume, your education section is going to be of particular importance.

How to create the best sales resume education section

Sales is a unique profession that doesn’t usually put as much emphasis on education when being hired.

Don’t get me wrong, a strong degree or college diploma in business administration or marketing is going to help you for sure, it’s just not usually the #1 factor for getting or not getting the job.

If you’ve been in sales for several years, you won’t have to put as much emphasis on education on your sales resume as a newcomer or fresher in sales.

If you’re applying for your first job in sales then you’re going to want to expand the details of your education where possible.

Here’s what you can add to your education section:

• Relevant courses (here you can mention projects, skills acquired, lessons learned, etc.)
• Your GPA (if you think it’s relevant)

Here’s a look at how a sales industry veteran’s education looks compared to someone who is writing a resume with no sales experience.

This person graduated 10 years ago, so it’s not necessary to include many details about their education. This degree acts as an anchor or foundation that their sales experience was built on. In this case it serves to be a box that is checked by the HR team that you have a university education.

Here is an entry level sales education section example:

• • Specialised in Biostatistics
• • Worked phone banks to solicit donations during university pledge week
• • Participated on the university debate team, placing in the top 5 at 4 tournaments

You can see that by expanding on the experiences you may have had at university creates a list of sales experience even when you didn’t actually have a paying job as a salesperson. Hiring manager take note of sales resumes that do this.

How to include skills on your sales resume

There are two basic approaches to including your skills. The way you go about it will depend on whether you’re describing technical or soft skills.

Let’s break down the difference and how to do each one the best way.

How to include technical skills on a sales resume

Most of the technical skills required in sales have to do with software for lead and customer management or presentations.

You’re either familiar with the software or you’re not. There isn’t really a need to elaborate beyond that.

This kind of a skills section is important because many ATS (Applicant Tracking Systems) will screen your resume for certain keywords before a human ever sees it. A simple list of relevant technical skills required in the job description does the job perfectly.

The top sales resume technical skills

• Microsoft Dynamics
• Propeller CRM
• Google Hangouts Meet

How to include soft skills on a sales resume

While technical skills are becoming more and more important in sales, the industry is still build on soft skills.

But just listing them isn’t going to cut it. Anyone can say they have good people skills or are well organized.

To stand out, you need to show that you have those skills by giving examples.

Most big companies use ATS systems to automatically scan resumes for keywords. So, be sure you list your skills as closely to how they’re listed in the job description (more on how to do that later).

Here, you can see that someone scanning your resume can quickly see which soft skills you possess and that you’re serious about backing them up. Right away, this is going to distinguish you from most of the other sales resumes they’ve seen.

Whether you’re a retail sales associate working in a store or an outside sales manager with high-ticket clients, speaking to customers to uncover their needs and present them with the right offer is crucial.

This skill flows well into account management, which covers the long term communication with clients.

The end goal here is retaining high value users and upselling current customers to new services or add-on products. It’s where the bulk of profit for many businesses comes from, as this expansion revenue requires a lower investment from companies compared to acquiring completely new customers.

The top sales resume soft skills

• Dealing with Objections
• Cold Calling
• Public Speaking Personal Ethics
• Highly Driven
• Door to Door Sales
• Active Listening
• Negotiation
• Pitch Delivery
• Emotional Intelligence
• Goal-Oriented
• Authenticity
• Communication
• Creating Good Rapport
• Public Speaking
• Relationship Building
• Writing Reports

4 steps to follow when adding skills to your sales resume

Follow these four steps to match what the employer is looking for to maximize your chances of getting hired:

• Read the job description carefully and write down all of the skills it mentions.
• Then list all of your own skills. These could be hard skills like knowing a language or soft skills like working well in groups.
• See which skills match up - they don’t necessarily have to be exact matches, to raise a flag for you.
• Don’t just list the keywords - demonstrate you have these skills by giving examples from your past experience.

When it comes to sales, there are specific skills that make for a great salesperson - these have to do mainly with communicating with customers and transforming leads into high-value customers.

Choosing the right technical and soft skills for a salesperson resume

Remember your sales resume isn’t just a resume, it’s an answer to a specific job.

So, you should make sure that sales skills and keywords you use are tailored to that job posting.

Let’s take some text from a Sales Representative job offered by The Kellogg Company:

• Selling , negotiating , and executing business plans – The data doesn’t lie. You’ll utilize your tried and true fact based selling techniques to grow Kellogg’s in-store sales.
• Patience + Persistence = Profit – It’s time to put your can-do attitude to the test. You’ll be a champion for Kellogg by implementing creative ideas and innovative solutions to overcome roadblocks , selling within the grocery landscape .
• Excel, PowerPoint, Nielsen …Oh My – Showcase your savvy working with these applications to create a compelling sales story at every store.
• Drive Results – You will be accountable for delivering on key metrics such as POS (Point of Sale) budget, call coverage , and maintaining “perfect shelf” discipline … just to name a few.

YOUR RECIPE FOR SUCCESS

• High school diploma or equivalent
• Access to an approved* personal smartphone with Android or IOS operating system connected to a cellular network while working
• Intermediate technology skills such as Microsoft Office Applications, Internet , Cellular use
• Strong problem solving , influencing and negotiation skills
• Demonstrated use of excellent interpersonal skills
• Excellent written and verbal communication skills

Bonus Points :

• Bachelor’s Degree in business or related field
• Proficiency working in Microsoft Word, Excel and PowerPoint
• PREVIOUS EXPERIENCE WITH WALMART

Now let’s pick out the keywords and skills that someone applying to this job should mention:

Selling, negotiating, creative ideas, innovative solutions, problem solving, negotiation, interpersonal skills (all of these should be backed up with examples)

Microsoft Word, Excel and PowerPoint, Nielsen (these can be listed as technical skills)

PREVIOUS EXPERIENCE WITH WALMART (this should be highlighted with specific examples on how you worked with them)

This is only a portion of the requirements, but it’s already clear that you’ll have a lot of soft skills to demonstrate. When this happens, you can go beyond simply listing them in their own section and try to ensure they are mentioned and backed up in your experience, education, or other resume sections.

Adding certifications to your sales resume

This can be done similar to your technical skills section, or you can add CSP after your name at the top if that’s your only relevant certification. Just be sure to mention any certifications the job offer specifically asks for or mentions.

Top Certifications to Include on a Sales Resume

• Challenger Sales
• Spin Selling
• Sandler Training
• Certified Sales Professional CSP

Other sections you might want to consider

As a sales manager, sales associate or business development director you know that having a unique selling proposition is a major advantage.

Adding creativity and personality is your way to do this on a sales resume.

Before you go too crazy with this creativity you have to keep in mind that your resume is going to be read by a human with their own preferences and biases. As much as possible, you have to craft your resume to match that person or organization.

If you know the company you’re applying to is very traditional, then keep your resume that way. If the company pushes culture and personality a lot on its website and in the way it presents itself, it makes sense to reflect this on your own resume.

One way to approach it is to consider culture fit. Emphasize elements of your personality that match with the company. Just like with the experience above, you want the person reading your resume to get the feeling “This person seems perfect for us.”

For example, if you see the company likes to go hiking for an annual retreat, mention that you love to hike. Small details like this can help make you feel like the perfect candidate.

Or, if there were specific books or motivational speakers which had a major impact on how you approach sales, listing them is a great way to combine a bit of personality and some insights into what kind of salesperson you are.

For even more tips and advice about additional sections in your resume for sales jobs, check out our guides:

• Language skills
• Hobbies and interests
• Volunteer work
• LinkedIn on Resume
• Resume Awards
• Publications

Cover letter for sales representative

In case the job description says you need to provide a cover letter, do include yours. Otherwise, you can always leave it out.

Nowadays, job application forms include questions like “why do you want to work here”, or “explain why you’re the best fit for us”, which makes you wonder are cover letters really necessary ?

Still, they help you tell your story in a way that, if written right, it’s captivating and engaging.

In any case, you should pay close attention to the following tips when a cover letter is a must:

• Make sure you go over a cover letter checklist , not to forget what your cover letter should say ;
• Match the cover letter design with your resume’s;
• Address your cover letter properly;
• Keep an eye on your cover letter length ;
• Use a proper cover letter ending ;

If you need more inspiration, check out this example Sales cover letter .

Key takeaways: what makes a great sales resume?

• Choose a resume layout that sends the message you want and fits your experience level.
• Create a resume header that shows your sales certifications and makes sure you’re easy to contact.
• Make sure your resume objective or summary is very specific about your sales experience, accomplishments, and future goals.
• Your sales experience has detailed metrics and specific examples showing the impact you’ve had in your role.
• Any soft skills you list are backed up with examples.
• You list all the technical skills you have which match the job description.
• Your resume has a bit of personality designed to show you have the right soft skills and will be an excellent culture fit.

Sales resume examples

Explore additional sales resume samples and guides and see what works for your level of experience or role.

A typical sales resume is going to focus heavily on their performance in previous sales roles. That’s where the challenge of an entry level salesperson resume comes in. Fortunately, there are other ways to show you’ve got sales skills and the right attitude to learn.

Consider whether you’ve had experiences which showed persuasion, determination, passion, or just ingenuity. These examples can demonstrate you have what it takes to thrive in a sales position even without any formal work experience.

Beyond this, you need to show you’re ready to learn. Show you’re eager to get out there and grow to really stand out.

Finally, you can show you have what it takes for an entry-level sales position with more than just the resume. Make sure your communication skills shine during the whole application process. Write your resume and cover letter in a concise but persuasive manner. Follow-up with an email to keep the hiring manager engaged and after an interview be sure to send a thank you letter.

• Show that you can hit and exceed sales targets, communicate effectively, and manage your leads.
• Showcase your qualities as a sales representative clearly, through extremely specific examples.
• Display customer-related experience, e.g. account representative, support background, or any other experience that strengthens your ability to work with people’s needs.
• Make you memorable and prove culture fit by demonstrating your personality, e.g. by adding information about your passions and side projects.

• Strike a balance between demonstrating strong sales skills and the skills it takes to manage a team.
• Demonstrate the impact you’ve brought to previous companies you’ve worked for. Don’t be shy about using the numbers that will help your case.
• Demonstrate leadership skills as a sales manager by talking about your team and the progress you’ve helped it achieve. This could be an increase in sales results, a role in hiring new employees, or mentoring existing ones.
• Include references from higher-ups. For a sales manager role, you can also add references from your team. This is a good way to show your managerial experience from their perspective.
• Demonstrate you can push to complete work on time and get these past few clients before the close of the quarter.

• Are very product-driven, e.g. they demonstrate passion for the product or the ability to learn more about it
• Combine good personality with customer service skills that get results
• Demonstrate genuine interest in the target industry through product knowledge and relevant detail
• Display expert communication skills in the real world context, and NOT routinely list them in the Skills section
• Showcase your personality through custom “Most proud” and “How I spend time: resume sections

• Show why you’re better than the somewhat notorious car salesman stereotype
• Starts with being specific. Don’t just list your responsibilities from previous jobs, talk about the numbers. How many vehicles did you sell, what was the % improvement?
• Includes information about upselling and offering add-ons to customers -- after all, that’s where the bulk of your profit comes from.
• Covers communication and people skills just as well as hard sales numbers.
• Include examples of assessing customer needs and working with different types and tax brackets of clients.

A director of sales has a lot on their plate and their resume will need to reflect the increased number of requirements for such an important position.

The first and most important point you need to get across is that you improve the company’s sales strategy. Some key components, depending on the industry, would include pipeline volume growth, reducing sales cycle length, and ultimately increasing the average purchase volume and growing monthly sales revenue.

Make sure you include relevant numbers for each of the improvements you’ve worked on. After all, if you’re in sales, you know that numbers speak for themselves.

Your director of sales resume wouldn’t be complete without a focus on leadership skills. Talk about your experience managing sales teams, mentoring mid-level management, and improving team effectiveness.

The position of director of sales is multifaceted and there’s a lot of other information you may want to include on your resume. Take a moment and think what has made an impression on you when recruiting for your own sales teams. This can be specific sales results, but most often memorable candidates include something in their resume that shows their personality and demonstrates culture fit.

Looking to build your own Sales resume?

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Our collection comprises free services and those that make use of professional writers’ skills. Some options require a subscription or one-time payment.

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Super Star Resume - Best Resume Builder Overall

Star Rating: 4.9/5

Super Star Resume is an innovative resume builder that completely transforms creating professional resumes. By offering a user-friendly interface and a range of powerful features, Super Star Resume enables individuals to produce exceptional resumes that effectively showcase their abilities, accomplishments, and work history.

• Skilled and seasoned writers
• Customized strategy aligned with unique career objectives
• Timely delivery of resumes
• More significant expense compared to certain other resume writing services
• Restricted selection of additional services
• Availability may be restricted depending on demand and geographic location
• Intuitive resume builder: An intuitive interface that simplifies the resume creation process, offering modern templates for a professional look.
• Customization choices: Users can personalize their resumes by selecting from various font styles, colors, layouts, and sections to align with their unique style.
• Comprehensive content suggestions: Access to a collection of expertly curated bullet points, action verbs, and industry-specific phrases to craft impactful resume content.
• Real-time previews and editing: Real-time previewing and editing capabilities ensure a visually appealing and error-free final resume.
• Integration with professional networking platforms: Integration with LinkedIn allows users to maintain consistency between their online presence and resume.
• Tailored resumes for different job applications: The duplication feature facilitates the creation of multiple resume versions, each customized for specific job applications or industries.
• Resume analytics and tracking: Users can monitor the views and downloads of their resumes, gaining valuable insights to optimize their job search strategies.
• Professional Resume : $169
• Resume With Cover Letter : $199
• All-Included : $199

>> Use Super Star Resume to Secure Your Dream Job

ZipJob - Best Resume Builder for Guarantees

Star Rating: 4.7/5

ZipJob is widely regarded as an excellent option for resume creation, especially for those who value guarantees. Their impressive 60-day assurance ensures that individuals searching for employment will experience a surge in interview invitations within this period.

If this desired outcome cannot materialize, ZipJob proactively offers a complimentary review and revision of your resume. This guarantee highlights their commitment to client contentment and showcases their unwavering belief in the superior quality of their resume writing services.

• The starting package is cost-effective
• Complimentary ATS check included
• 60-day interview assurance with higher-tier packages
• The design and layout made it challenging to read the resume
• The summary section was overly lengthy and filled with clichés
• The formatting of the education and training sections was subpar
• Expert resume writers: ZipJob provides access to a team of expert resume writers with the skills and knowledge to review, evaluate, and optimize your resume for compatibility with Applicant Tracking Systems (ATS) and hiring managers.
• ATS optimization: Meaning they ensure your resume is structured and formatted to navigate and succeed in ATS filters effectively. Employers commonly use these filters to assess and rank resumes during the initial screening process.
• Keyword optimization: The resume builder online offered by ZipJob assists you in identifying and integrating pertinent keywords and industry-specific terminology. This practice heightens the visibility of your resume, making it more likely to capture the attention of hiring managers.
• Job-specific content suggestions: ZipJob provides valuable advice regarding the most relevant and influential content to include in your resume for different job titles and industries. This guidance is invaluable in customizing your resume for specific roles.
• Cover letter writing assistance: ZipJob supports the creation of impactful cover letters that complement your resume, strengthening your overall job application.
• Unlimited revisions: One noteworthy feature of ZipJob is the option for unlimited revisions and updates to your resume. This ensures that your resume not only meets but continues to meet your specific requirements and mirrors your professional growth.
• Collaboration with resume writers: the platform facilitates direct collaboration with the resume writers, enabling you to share additional information, discuss specific requirements, and seek clarifications at any stage of the resume creation process.
• Launch Package: $139 (or $48/mo)
• Fast Track Package: $189 (or $65/mo)
• Premium Package: $299 (or $27/mo)

>> Use ZipJob to Secure Your Dream Job

Resumeble - Best Resume Builder With Custom Bundles

Star Rating: 4.3/5

Resumeble is a highly efficient and user-friendly resume builder that empowers individuals to create professional and compelling resumes. With Resumeble, crafting a standout resume becomes a streamlined process thanks to its intuitive interface and extensive range of customizable templates.

Whether you’re a recent graduate, a seasoned professional, or someone looking to change careers, Resumeble caters to all needs and skill sets. It offers helpful suggestions and expert advice to ensure your resume showcases your unique qualifications and achievements in the best possible light.

• A 60-day interview guarantee is included
• Budget-friendly package deals are available
• It’s more established than some other websites
• Keyword optimization: This feature helps optimize your resume by suggesting relevant keywords aligned with your target industry or job, enhancing your visibility to Applicant Tracking Systems (ATS) and recruiters.
• Content import: Resumeble allows you to import your existing resume or LinkedIn profile, saving you the time and effort of manual data entry.
• Real-time editing: You have the convenience of editing and modifying your resume in real time, providing the flexibility to experiment with various formats, sections, and content.
• ATS compatibility: Resumeble ensures your resume is ATS-compatible, essential for better visibility and a higher chance of being shortlisted by employers using Applicant Tracking Systems.
• Download options: The platform offers various download formats, including PDF, Word, and plain text, ensuring compatibility with diverse application processes.
• Cover letter builder: Resumeble features an integrated cover letter builder, streamlining the creation of professional and personalized cover letters that complement your resume.
• Career Pro Package : $159.00
• Professional Package : $299.00
• Premium Package : $399.00

>> Use Resumeble to Secure Your Dream Job

Let’s Eat, Grandma - Best Resume Builder for Range of Career Service

Star Rating: 4/5

Let’s Eat, Grandma is an inventive and progressive tool for creating impressive resumes. The platform streamlines the resume-building process, making it easier for job seekers to craft exceptional resumes. With Let’s Eat, Grandma, individuals can create unique resumes that catch the eye of employers and set them apart from the competition.

This user-friendly platform offers a range of customizable templates that allow users to tailor their resumes to showcase their specific skills and experiences. Let’s Eat, Grandma also provides expert advice and recommendations to help ensure that your qualifications and achievements are effectively highlighted in your resume.

• Complimentary resume evaluation
• Choices available for individuals from entry-level to executive-level positions
• Extensive collaboration opportunities
• Not specialized in academic CVs or federal resumes
• Relatively higher pricing compared to some other services
• Potential for a longer turnaround time compared to competing services
• Expert choice: You can save your resume in multiple formats (PDF, Word, plain text) or easily share it with potential employers via email or a link, simplifying the distribution of your resume.
• Error highlighting: The builder can identify potential errors, inconsistencies, or missing information within your resume and provide suggestions or alerts for improvement.
• Section prompts: Pre-written prompts for various resume sections (e.g., work experience, education, skills) can help you structure your resume effectively and ensure you include essential details in each area.
• Customizable sections: You can add, remove, or rearrange sections to tailor your resume to emphasize your strengths and relevant experiences.
• Keyword optimization: The resume builder can recommend industry-specific keywords based on the job description, enhancing your resume’s chances of passing through Applicant Tracking Systems (ATS) and grabbing the attention of hiring managers.
• Starter Package : Priced at $439, but there is an anti-inflation sale price of $389.
• Accelerated Package : $549.
• The premium Package : $689, but the anti-inflation sale price is $614.
• Executive Concierge Service : $1,899 or as low as $119/month.

>> Use Let’s Eat, Grandma to Secure Your Dream Job

ResumeSpice - Best Resume Builder for Job Seekers of Any Level

Star Rating: 3.8/5

ResumeSpice , a renowned online resume builder, streamlines crafting professional resumes. This platform provides job seekers with a user-friendly interface and a wide selection of templates, enabling them to create impressive resumes that align with their career objectives.

With ResumeSpice’s seamless experience, users are guided through each resume section effortlessly while receiving valuable tips throughout the process. From personal details and work history to skills and accomplishments, this platform ensures that all crucial aspects of a resume are comprehensively addressed.

• Additional assistance
• Timely service
• ATS optimization
• Guaranteed interviews
• Restricted revisions
• Insufficient customization options
• Restricted refund policy
• User-friendly interface: ResumeSpice boasts an intuitive and user-friendly platform, simplifying the resume creation process and offering a seamless experience to users.
• Extensive template library: The platform offers a vast selection of professionally designed templates tailored to various industries and job positions. Users can explore different styles and layouts to find the perfect match for their needs.
• Import and export options: ResumeSpice enables users to import their existing resumes in formats like PDF or Word for easy editing and updates. Users can conveniently export their finalized resumes in multiple formats, facilitating sharing with employers or uploading to job portals.
• Mobile-friendly design: ResumeSpice is optimized for mobile devices, allowing users to create and modify their resumes using smartphones or tablets.
• Cloud storage: The platform provides secure cloud storage for users’ resumes, ensuring accessibility and updates from any device with an internet connection.
• Resume tracking: ResumeSpice includes tools for tracking the performance of submitted resumes, such as monitoring views, downloads, and application outcomes. These features empower users to evaluate their progress and make data-driven enhancements to their job search strategies.
• Entry Level Resume : $479
• Professional Resume : $589
• Executive Resume : $699

>> Use ResumeSpice to Secure Your Dream Job

TopResume - Best Resume Builder for Customer Service

Star Rating: 3.6/5

TopResume is an outstanding resume builder explicitly tailored for customer service professionals. It offers a seamless and user-friendly experience, enabling users to create exceptional resumes effortlessly. The platform goes beyond just providing a basic resume template, offering valuable suggestions and tips to optimize the content.

This ensures that each resume created on TopResume is unique and attention-grabbing in the highly competitive job market.

Besides its user-friendly interface, TopResume provides expert review services. These services allow skilled professionals to provide personalized feedback on resumes, helping enhance their overall quality further. By leveraging this feedback and incorporating attention to detail, customer service professionals can create compelling resumes that effectively capture the attention of potential employers.

• Streamlined registration process
• Well-designed and formatted one-page resume
• The summary and Job Scope sections were overly extended
• The training section needed to have prominence
• Skill-based sections: The resume builder features dedicated sections highlighting essential customer service skills, including communication, problem-solving, conflict resolution, and relationship building.
• Expert review services: TopResume provides expert review services where experienced professionals offer personalized feedback and recommendations to enhance the overall quality of your resume.
• ATS compatibility: The platform ensures that the resumes created are compatible with Applicant Tracking Systems (ATS), which employers commonly use for scanning and filtering resumes.
• Download and sharing options: Users can download their resumes in various formats, such as PDF or Word, and easily share them with potential employers or upload them to job portals.
• Industry-Specific Tips: TopResume offers industry-specific tips and guidance to assist users in tailoring their resumes to the customer service field, helping them stand out among competitors.
• Cover letter builder: Besides resume building, TopResume provides a builder that empowers users to craft professional and compelling cover letters customized for customer service roles.
• Mobile accessibility: The platform is mobile-friendly, allowing users to create, edit, and update their resumes while on the go, using their smartphones or tablets.
• Entry level : Up to 200$.
• Professional level : Up to 200$-400$.
• Executive level : Up to $350-$700.

>> Use TopResume to Secure Your Dream Job

Resume Writing Services - Best Resume Builder for Affordability

Star Rating: 3.3/5

While Resumewritingservices.org may be a different size than its competitors, it stands out due to its team of talented and experienced resume writers. The website is user-friendly and provides exceptional service. However, this service’s true strength lies in its writers’ expertise.

Resumewritingservices.org sets itself apart by offering a comprehensive consultation process and goes beyond expectations by providing unlimited calls with its resume writers. This personalized approach distinguishes them from other companies and guarantees each client receives individual attention and support.

• Experienced resume writers of the highest caliber
• Unlimited phone consultations and revisions
• More expensive than rival services
• A limited range of products
• Skilled and experienced resume writers: Resumewritingservices.org takes pride in its team of highly trained and professional resume writers who possess a deep understanding of crafting effective resumes.
• Personalized service: Resumewritingservices.org offers a personal touch by providing unlimited calls with their resume writers. This unique feature allows clients to engage in direct communication and close collaboration with the writers throughout the resume creation process.
• Competitive job market expertise: The writers at Resumewritingservices.org have knowledge of current job market trends. This ensures that the resumes they create are optimized to excel in today’s fiercely competitive job market.
• Quality Assurance: The service maintains a rigorous quality assurance process to guarantee that the resumes delivered to clients meet the highest standards and align with their expectations.
• Timely delivery: Resumewritingservices.org is committed to delivering resumes within the agreed-upon timeframe, ensuring clients receive their documents promptly.
• Client satisfaction guarantee: Resumewritingservices.org offers a client satisfaction guarantee, assuring clients are fully content with the final resume. The service is ready to provide revisions if necessary.
• Affordable pricing: Resumewritingservices.org provides pricing options that are competitive and transparent, making professional resume writing accessible to a wide range of job seekers.

Resumewritingservices.org employs a pricing system that is clear and easy to understand for their resume-building services. The initial package begins at $270 , including a comprehensive consultation with a skilled resume writer and developing an individualized resume.

They offer extra options that enable customers to personalize their packages based on their unique preferences. This adaptable pricing strategy guarantees that clients can choose the services that align with their requirements and financial constraints.

>> Use Resume Writing Services to Secure Your Dream Job

Craft Resumes - Best Resume Builder for Quick-Turnaround

Star Rating: 3/5

Craft Resumes stand out as a well-established writing and editing service known for its ability to deliver effective outcomes. Our dedication to providing a 24-hour turnaround guarantees you’ll receive the initial version of your resume promptly.

Navigating our user-friendly website is effortless, making it easy to use our services. At Craft Resumes, we specialize in crafting customized resumes to match your skills, qualifications, and aspirations for your career.

• Speedy completion
• Customized CVs
• Intuitive site
• Insufficient details
• Absence of assurances
• Quick turnaround: Craft Resumes commits to delivering the initial draft of your resume within 24 hours, ensuring a speedy and efficient service.
• Expert Writers: Craft Resumes prides itself on its team of experienced writers who possess expertise across various industries and stay up-to-date with current hiring trends. They’re dedicated to making your resume stand out and catch the attention of potential employers.
• Unlimited revisions: We provide unlimited revisions to guarantee your complete satisfaction. If you have specific changes or additions in mind, our team will collaborate with you closely to implement the modifications.
• Confidentiality and Privacy: At Craft Resumes, we prioritize the confidentiality and privacy of your personal information. You can trust that your data will be handled securely and with the utmost discretion.
• Tailored resumes: We specialize in tailoring resumes to align with your career objectives, industry, and job requirements. Each resume is personalized to accentuate your unique strengths and qualifications.
• Resume Writing : $229.00
• Basic : $279.99
• Optimal : $339.99
• All-In-One : $499.99

>> Use Craft Resumes to Secure Your Dream Job

Resume Companion - Best Value Resume Builder

Star Rating: 2.8/5

Resume Companion is a virtual platform and service that specializes in aiding individuals in creating resumes that are professional and impactful. It offers an array of resources and tools to assist job seekers in crafting interesting resumes that effectively showcase their skills, experiences, and qualifications.

A prominent feature of Resume Companion is its user-friendly resume builder. This tool allows users to select from various professionally designed templates and personalize them based on their specific requirements.

Users can effortlessly incorporate their personal information, employment history, educational background, skill set, and other pertinent details to produce a customized resume tailored to their needs.

• Intuitive user interface
• High-quality templates
• Efficiency-boosting functions
• Cost-effective choice
• Restricted editing features without subscription
• Absence of extensive customization options
• Limited availability of extra services
• Cover letter builder: Resume Companion goes beyond resumes and provides users with a tool for crafting customized cover letters tailored to specific job applications. This feature guides users through the process, helping them effectively present their qualifications and make a compelling case to prospective employers.
• ATS optimization: In today’s job market, many companies use Applicant Tracking Systems (ATS) to screen resumes. Resume Companion helps users ensure their resumes are ATS-friendly. The platform offers valuable tips and insights on incorporating relevant keywords, formatting the document correctly, and increasing the likelihood of passing through the ATS screening process.
• Educational resources: Resume Companion extends its services by offering an informative blog and educational materials that cover various aspects of resume writing, job search strategies, interview techniques, and career development guidance. These resources provide users with valuable insights and advice to help them create impressive resumes and enhance their job search efforts.
• Download and sharing options: Upon completing their resumes, users can conveniently download their documents in multiple formats, including PDF and Word. Resume Companion also makes it easy for users to share their resumes online or print them offline.
• Customer support: Resume Companion values user satisfaction and offers customer support to assist with users’ questions or concerns while utilizing the platform. Users can access support through email or the platform’s contact form.

Resume Companion provides a cost-effective solution for individuals seeking an all-inclusive service. It’s vital to remember subscription renewal is required to access future editing services. In summary, Resume Companion offers a wallet-friendly option for those who desire a user-friendly resume-building experience without needing advanced writing abilities.

>> Use Resume Companion to Secure Your Dream Job

Our Ranking Methodology for Best Resume Writing Services

To comprehensively and objectively rank the top resume writing services, it is essential to have a thorough methodology. The first step in this process was conducting extensive research and analysis. This involved gathering a comprehensive list of reputable resume-writing services from multiple sources such as online searches, customer reviews, industry directories, and personal recommendations.

• Feature analysis: Evaluate the functionalities provided by each resume builder, considering elements like template variety and quality, customization flexibility, user-friendly editing and formatting options, import/export capabilities, spell check and grammar tools, and integration with job search platforms and professional networks.
• Template collection: Examine the assortment and quality of templates. Look for a wide range that suits various industries, job levels, and design preferences, considering these templates’ aesthetics, readability, and contemporary design.
• Editing and customization: Scrutinize the adaptability and user-friendliness of the editing and customization tools each resume builder provides. Assess the capacity to add or modify sections, reorganize content, and tailor resumes to specific job requirements.
• User interface and experience: Analyze the user interface and the overall user experience each resume builder offers. Evaluate the ease of navigation, instruction clarity, guidance or prompts, and the platform’s responsiveness.
• Integration with job search platforms: Determine whether resume builders offer seamless integration with popular job search platforms and professional networks like LinkedIn or ATS systems. Consider how well the resumes can be transferred and their compatibility with these platforms.
• Additional resources: Evaluate if the resume builders provide extra resources such as sample resumes, tools for creating cover letters, interview tips, or career advice. Consider the breadth and practicality of these supplementary resources.
• Mobile-friendliness: Gauge the mobile-friendliness and responsiveness of the resume builders, recognizing the growing trend of mobile job searching and application processes.
• Customer support: Reflect on the accessibility and quality of customer support services, encompassing options like live chat, email support, or knowledge bases. Assess the responsiveness and helpfulness of the support team.
• Pricing and value for money: Appraise the pricing plans presented by the resume builders in terms of the value they offer based on features, usability, and overall service quality.
• Industry reputation: Consider the standing and trustworthiness of the resume builders, considering factors such as awards, recognition, partnerships, and user feedback from reputable sources.

Buyer’s Guide: Why Use a Resume Builder?

Crafting a well-crafted CV comes naturally to particular job seekers. However, even the most seasoned experts may need help in resume writing. If you find yourself in need of help with creating a compelling resume, here are several ways in which the best online resume builder can be beneficial:

Resume builders provide users with pre-designed templates and helpful tips, streamlining the process of writing a resume and alleviating stress.

Offers Writing Tips

Promoting oneself requires considerable effort. Only some people possess writing skills, even if they enjoy self-promotion. To showcase one’s experience and knowledge effectively, a resume builder can help select the most appropriate words and phrases.

Improves Design

In every field, there are unique standards for an impressive resume. If you need to gain knowledge in design or the tools, resume builders can provide free templates to enhance your resume’s visual appeal and quality.

Applicant Tracking Systems (ATS)

Recruiters often use ATS systems to scan resumes. A good resume builder will help with formatting to ensure that your resume is easy for these systems to read.

What’s the Best Resume Builder?

The ideal resume builder for each individual may differ according to their specific requirements. If you prefer a tool that offers step-by-step guidance in creating your resume, we suggest using a builder that provides helpful tips and recommendations. If you prefer a resume builder that auto-generates a summary, we recommend using a tool that extracts information from your LinkedIn profile.

For those who enjoy having creative control over their resumes, we suggest using a platform with features. By selecting the resume builder that aligns with your needs and suits your industry and personal style, you’ll significantly increase your chances of capturing the attention of hiring managers.

Resume Builder vs. Resume Writing Service: What Matters for You

When it comes to crafting a resume, there are three options available. You can opt to create it independently, use a resume builder tool, or enlist the services of a professional resume writer. Your best choice will depend on your writing abilities, available time, and financial resources.

Do-It-Yourself

You have the choice to construct a resume entirely by yourself. The benefit of this option is that it costs nothing but requires a significant amount of effort. Along with composing all the information, you must possess graphic design skills.

This approach works well if you have these abilities, but with them, your options for creating a resume are unlimited. To overcome this limitation, you can use a resume builder or enlist the help of a resume writing service.

Resume Builder

A tool for creating resumes allows you to input your details into a template, resulting in an original appearance and layout with no design work. The top resume building tools also offer suggestions on enhancing your resume and tailoring it to match the specific job you are applying for.

While you are still responsible for writing the content, once it is written, you can quickly transfer that information into any other template with just a few simple clicks. Some of these services are free and many like to promote themselves as such, but most require a small payment to download your finished resume.

Professional Resume Writing Service

Professional resume writing services are expensive, but they offer the convenience of handling all the work for you. An experienced writer will gather relevant information about your background and transform it into a unique and engaging resume.

The process typically takes a few days, and the level of originality in the outcome largely relies on your choice of company and writer. However, we will not delve into these services further in this guide.

Are Resume Builders Worth It?

Definitely, without a doubt. An effective resume creator will guarantee that your CV is formatted correctly to navigate Applicant Tracking Systems and ultimately reach the hands of recruiters.

Is It Unprofessional to Use a Microsoft Word Resume Template?

Relying on a template will not set you apart, and there is a high likelihood that your application will be dismissed because your resume is identical to those of other job seekers.

Final Thoughts

Choosing the right resume builder is crucial in today’s competitive job market. Creating a professional and impactful resume that stands out from the crowd can significantly impact your job search. With the right tool, you can save time, improve your chances of landing an interview, and ultimately secure your dream job.

When selecting a resume builder, consider your specific needs and priorities. Look for features like customizable templates, industry-specific examples, and the ability to export your resume in different formats. Consider user reviews and ratings to ensure you choose a reputable and reliable platform.

Remember, an exceptional tool for crafting resumes should give you the power to present your skills, experience, and accomplishments effectively. It should simplify and expedite creating a resume without hassle. Investing in a reliable resume builder is investing in your professional future.

Therefore, explore the different options available for resume builders. Test out their free trials or demos and choose the best fit for your objectives. Our top recommendation is Super Star Resume . This meticulously designed resume can open doors to exciting career prospects and be a dependable companion on your journey toward success.

Ahad Waseem is a business, blockchain, and cybersecurity writer who often takes on art, politics, and economics too. As a linguistic engineer who writes to solve problems, he’s written for various tech and business publications. When he’s not writing, he’s probably on horseback, caring for his houseplants, or training Bonsai trees. He can be reached at [email protected] . McClatchy’s newsrooms were not involved in the creation of this content. We may earn a commission if you make a purchase through one of our links.

©2023 Miami Herald. Visit miamiherald.com. Distributed by Tribune Content Agency, LLC.

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• Moscow State University: The tallest of Moscow's Seven Sisters, it's been housing the State University since 1953, being the tallest educational building in the world with its 240m of height.
• Zuev Workers' Club: Projected by Ilya Golossov to be a recreational center for factory workers, its construction was finished in 1929 and it's still a reference in Constructivist architecture.
• Spasskaya Tower: Overlooking the Red Square, this clock tower on the Kremlin's walls was built by Milanese architect Pietro Antonio Solari back in 1491, and once the Kremlin's main entrance.
• State History Museum: The State History Museum complex has been open since 1872, and houses many artifacts, varying from pre-historical relics to artworks acquired by the old royalty.
• Mercury City Tower: The 5th tallest builing in Russia and Europe overall, this 338m tall skyscaper in the International Business Center stands out for its copper glass façade and spiky shape.
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assignment of choses in action in nigeria

Nigeria: Assignment Of Choses In Action

• INTRODUCTION

As a general rule and based on the doctrine of privity a contract cannot confer rights or impose obligations on any person except the parties to the contract. Accordingly, a contract cannot be enforced by or against a person who is a stranger to it even if the contract is made for his benefit and purports to give him the right to sue or to make him liable upon it. The main reason for this is that it is the parties' contract, and they are always free to vary or discharge it by agreement. The creation of a third party right would impede this freedom unless an agreement for such third party involvement has been made part of the agreement. 2

As with every general rule, there is always an exception. One of the exceptions to the doctrine of privity of contract arises in the assignment of choses in action where the owner of a contractual right can transfer same to a third party without the consent of the debtor (the counter-party to the contract), thereby enabling the third party to enforce the right against the debtor. The process of transfer of such a right is known as "assignment" and the types of property which are susceptible to this type of transfer are known as "choses in action." 3

This article sets out to trace the evolution, incidence, and the conditions precedent for a valid assignment of choses in action under Nigerian law.

• WHAT ARE CHOSES IN ACTION?

Choses in action is a legal expression used to describe all personal rights of property which can only be claimed or enforced by action and not by taking physical possession of them. They are also called "things in action" because they are things which a person is not possessed but has to bring an action in court in order to recover them. 4 Choses in action may be legal or equitable. Legal choses in action are those which could historically only be enforced by an action at common law whilst equitable choses in action are choses in action which could only be enforced in the courts of equity- they arose out of property rights over which the Chancery Court formerly had exclusive jurisdiction. 5 Examples of choses in action include debts, shares, negotiable instruments, policies of insurance, bills of lading, patents, copyrights, rights under trusts and legacies, 6 benefit of a contract for sale of reversionary interest, rights to claim indefinite sums of money, as for compensation under Statute; damages for loss in which the assignee was the assignor's insurer, a debt or benefit arising out of an existing contract, but payable at a future time 7 and a claim for damages in tort. 8 All these are intangible rights which cannot be physically possessed but only claimed or enforced by an action in court. They are in law permitted to be assigned by the holders (though they can neither be seen nor possessed) to third parties who would be able to enforce the rights against the debtors even though they were not parties to the original contract.

• ASSIGNMENT OF CHOSES IN ACTION

The term "assignment" refers to the act of transferring to another all or part of one's property, interest, or rights. The term denotes not only the act of transfer, but also the instrument by which it is effected. 9 In Julius Berger (Nig) Plc & Anor v. Toki Rainbow Community Bank Ltd 10 the Court of Appeal held that "assignment means to give something to some body for their use or benefit. It also may mean to transfer right, property or title from the persons legally entitled to them to some body else for their benefit."

The assignment of choses in action may be legal or equitable. Due to the vagaries of the historical evolution of law and equity, different considerations apply to the assignment of choses in action at law and in equity. 11

• ASSIGNMENT AT COMMON LAW

Historically, under common law contractual rights were hitherto not assignable without the consent of both contracting parties since they were things in action as opposed to things in possession. This common law rule stemmed from the difficulty of conceiving of transfer of an intangible, and the desire to avoid maintenance and champerty. 12 The only methods of assigning contractual rights at common law were by novation and by procuring the debtor's acknowledgment that he held for the assignee, both of which required the consent of the debtor, unless the assignment was done by the king or it involved the assignment of a mercantile chose in action like a negotiable instrument which are transferrable by mere delivery. Accordingly, legal choses in action could only be assigned at law with the consent of the debtor. The assignor was however, required to be joined as a party to any action to enforce the assignment (either as a plaintiff if he consented or as a defendant in the absence of consent) since there was no privity of contract between the debtor and the assignee.

Given the rigors of assignment of legal choses in action under the common law, the courts of equity developed more flexible requirements for the assignment of equitable choses in action. However, the most significant intervention was introduced by the enactment of the English Judicature Act of 1873 13 which introduced the concept of statutory assignment.

• STATUTORY ASSIGNMENT

The enactment of the Judicature Act, 1873 (a statute of general application in Nigeria) 14 created an exception to the doctrine of privity of contract by introducing the concept of trust of a chose in action in section 25(6) 15 of the Act, which provides as follows:

Any absolute assignment by writing under the hand of the assignor (not purporting to be by way of charge only) of any debt or other legal thing in action, of which express notice in writing has been given to the debtor, trustee or other person from whom the assignor would have been entitled to claim such debt or thing in action, is effectual in law (subject to equities having priority over the right of the assignee) to pass and transfer from the date of such notice;- (a) The legal right to such debt or thing in action (b) All legal and other remedies for the same and (c) The power to give a good discharge for the same without the concurrence of the assignor; Provided that if the debtor, trustee or other person liable in respect of such debt or thing in action has notice:- i. That the assignment is disputed by the Assignor or any person under him or; ii. Of any other opposing or conflicting claim to such debt or thing in action, he may if he thinks fit either call upon the person making claim hereto to inter plead concerning the same, or pay the debt or other in action in Court.

By section 25(6) of the Judicature Act, a contractual party could assign his rights under the contract subject to the conditions stated in the Act without any need for a novation or acknowledgment by the debtor.

• CONDITIONS FOR A VALID ASSIGNMENT OF CHOSES IN ACTION

In order for Section 25(6) of the Judicature Act 1873 to apply, three conditions must be fulfilled:

• The assignment must be absolute and not purport to be by way of charge only

An absolute transfer is a transfer of the whole not a part of the chose in action. The test to be applied in determining whether an assignment is absolute is whether the assignor has unconditionally transferred to the assignee for the time being, the sole right to the debt in question as against the debtor in which case the assignment is absolute. The fact that the assignee is to hold proceeds of the debts or the surplus proceeds beyond the stated amount, on trust for the assignor does not prevent the assignment from being absolute. 16

An assignment that purports to be by way of charge only is not an absolute assignment. The relevant test is to decide whether the assignment merely gives a right to the assignee to payment out of a particular fund by way of security rather than an unconditional transfer of the fund to the assignee. The judicial reasoning behind the requirement for an absolute assignment is that the debtor should not be put in doubt or jeopardy by the arrangements between the assignor and the assignee as to whom he is to discharge his obligations. 17

No particular form or mode is prescribed or required by law for a legal assignment as long as the assignor absolutely and unequivocally indicates the transfer of the benefit, interest or title to the assignee. 18

• It must be in writing under the hand of the assignor

No particular mode or form is necessary as the writing can be informal, as for instance, a direction in writing by a creditor to his debtor to pay the assignee, handed to the assignee, may amount to an assignment but such a direction handed to the debtor may not by itself constitute an assignment unless there is evidence that the assignee has requested or consented to it. It is also the law that even if the debtor has the direction, it may not constitute more than authority to pay, and gives the assignee no rights unless the instructions can be said to amount to an irrevocable mandate to the debtor. 19

• Express notice in writing thereof must be given to the debtor or trustee

This notice is not required to be in a separate document purposely prepared as a notice and described as such. What is needed is that information relative to the assignment shall be conveyed to the debtor, and that it shall be conveyed in writing. A written demand for payment sent by the assignee to the debtor has been held to be sufficient once the notice is unconditional and given to the debtor personally before the assignee commences his action. It has also been held that since a creditor can assign by directing his debtor to pay the assignee, a single written document would suffice to constitute both the Assignment as well as the notice envisaged by the Act. 20 Furthermore, it is not necessary for the notice to the debtor to be given by the assignor or the assignee; it may be given by a third party. 21

• LEGAL EFFECT OF A STATUTORY ASSIGNMENT

Once the above conditions have been fulfilled, certain legal consequences immediately follow:

• The assignee can sue the debtor in his own name instead of having to sue in the name of the assignor and perhaps to go to the Court of equity to compel his joinder in the action. 22
• Consideration is not required for the assignment. 23
• The consent of the assignee is not required for the assignment. However, where it is the liabilities or the burdens under a contract that are to be assigned to a debtor, the consent of the assignee is required. 24
• EQUITABLE ASSIGNMENT OF CHOSES IN ACTION

An equitable assignment of a chose in action arises in the event of an assignment of an equitable chose in action and where there has been a failure to comply with the statutory conditions for a valid assignment of a legal chose in action. Such an assignment which fails to comply with the requirements of the statute will not become invalid but will operate as an equitable assignment.

An equitable assignment may be in writing or oral. It may operate by way of a charge only or be part of the debt or chose. If there is an equitable assignment of an equitable chose in action the assignment being absolute, then the assignee is entitled to sue in his own name. 25

Any words will suffice provided they are unambiguous to the effect that an identifiable debt has been made over by the creditor to some third person. 26 No privity of contract or consideration is required for equitable assignment provided that the assignor has, at the material time, done all that he can to perfect the gift. 27

An equitable assignment is binding even without notice to the debtor. However, as a matter of practice, notice to the debtor is very important for three reasons: 28

• In the absence of notice the debtor is entitled to discharge his obligations to the assignor and not to the assignee, whereas if he has notice he does so at his own peril and he may well be required to discharge the obligation a second time to the assignee with no entitlement to recovery from the assignor.
• The giving of notice to the debtor has an effect on prior equities. The general rule as regards assignment of choses in action is that an assignee takes subject to the equities that already apply to the property in question. Thus, anyone who has a prior interest (legal or equitable) in an assigned chose is entitled to a higher priority than that of the assignee. The reason for this is that the assignee cannot acquire a better title than that of the assignor. What he essentially gains by virtue of the assignment is a right to continue in the stead of the assignor in respect of that chose and nothing better. 29 Claims of equities that arise after notice of the assignment has been given to the debtor would not affect the assignee, except where the claim is very closely related to the original transaction upon which the chose came into existence. The rule that the assignee takes subject to equities will not apply where the trustee is estopped, either by conduct or deed, from setting up equities against the assignee. It would not also apply where the agreement occasioning the original transaction includes a clause that the assignees of the assignor would take free from all equities. 30
• The date of notice establishes the order of priority as between successive assignees. Thus, where there are two or more assignees of the same chose in action, the first to give notice has priority over the other assignees even if they were first in time. 31

Assignment of choses in action provides a veritable avenue for the exchange of contractual rights, especially when the assignor does not have the wherewithal to enforce the right in court. This creates a win-win situation for the assignor and the assignee, as the assignor is immediately able to receive value for his rights and the assignee is able to enforce the right to receive whatever benefit he has contracted for whilst the debtor's position is not adversely affected. The parties, however, need to understand the applicable principles so that they would know the extent of any rights that they acquire in any given transaction.

1 Emmanuel Abasiubong Bassey, Senior Associate in the Dispute Resolution Department of S.P.A. Ajibade & Co., Lagos, Nigeria.

2 Makwe v. Nwukor & Anor (2001) LPELR-1830(SC) (pp 25 - 25 paras D - E).

3 See, Ben Electronic Co. (Nig) Ltd v. ATS & Sons & Ors. (2013) LPELR-20870(CA) (pp 62 - 98 paras A - E). It was however, held that the benefit of a contract is only assignable in cases where it can make no difference to the person on whom the obligation lies to which of two persons he is to discharge it. See, Tolhurst v. Associated Portland Cement Manufacturers Ltd (1902) 2 K.B. 660 at 668, (1903) A.C. 414 cited in Julius Berger (Nig) Plc & Anor v. Toki Rainbow Community Bank Ltd (2009) LPELR-4381(CA) (pp 24 - 25 paras E - C).

4 I. E. Sagay, Nigerian Law of Contract (first published 1985, 2nd Edn, Spectrum Books Limited, Ibadan, 2000) 516.

5 See, https://mcmahonsolicitors.ie/choses-in-action/ [accessed on 14th December 2023.]

7 See, Ben Electronic Co. (Nig) Ltd v. ATS & Sons & Ors ( supra ).

8 See, FCMB v. Essien (2022) LPELR-58699(CA) (pp 6 - 6 paras E - F).

9 See, FCMB v. Essien ( supra ).

10 Julius Berger (Nig) Plc & Anor v. Toki Rainbow Community Bank Ltd (2009) LPELR-4381(CA) (pp 24 - 25 paras E - C).

11 The following choses are however not assignable: (1) Salaries of public officials. This is because it is perceived that if allowed to assign their salaries, they may deprive themselves of their means of sustenance and thereby impair the efficiency which is most desirable for the public service; (2) Alimony- because the money is meant for the maintenance of the spouse and (3) Rights arising out of a contract for personal service.

12 Maintenance occurs when a third-party provides support for litigation without a just cause, by providing, for example, financial assistance. Champerty is an aggravated form of maintenance, where a third-party pays some or all of the litigation costs in return for a share of the proceeds.

13 (36 & 37 Vict.) CHAPTER 66.

14 In Nigeria, a statute of general application refers to refers to statutes which were in force in England on the 1st of January, 1900. They were to be applied by the courts in Nigeria as far as local circumstances permit. However, the Western Region is now exempted by virtue of Law of England (Application) Law of 1959. The West African Court of Appeal stated in Young v. Abina that it was not necessary for the statute to be in force in all of the United Kingdom, but it only had to be in force in England. See, https://www.learnnigerianlaw.com/learn/legal-system/englishlaw accessed on 12th December 2023.

15 Section 25 (6) of the Judicature Act i873 which has now been repealed and replaced substantially by Section 136 of the English Law of Property Act, 1925, in England.

16 See, Ben Electronic Co. (Nig) Ltd v. ATS & Sons & Ors. ( supra ). It has been held that the benefit of a contract is only assignable in cases where it can make no difference to the person on whom the obligation lies to which of two persons he is to discharge it. See, Tolhurst v. Associated Portland Cement Manufacturers Ltd (1902) 2 K.B. 660 at 668, (1903) A.C. 414 cited in Julius Berger (Nig) Plc & Anor v. Toki Rainbow Community Bank Ltd (2009) LPELR-4381(CA) (pp 24 - 25 paras E - C).

17 See, https://www.designingbuildings.co.uk/wiki/Legal_and_equitable_assignment [accessed on 14th December 2023].

18 See, Julius Berger (Nig) Plc & Anor v. Toki Rainbow Community Bank Ltd (2009) LPELR-4381(CA) (pp 25 - 26 paras D - D).

19 See, Ben Electronic Co. (Nig) Ltd v. ATS & Sons & Ors ( supra ).

21 See, Bateman v. Hunt, 20 T. L. R. 628.

22 See, Ben Electronic Co. (Nig) Ltd v. ATS & Sons & Ors ( supra ).

24 See, Julius Berger (Nig) Plc & Anor v. Toki Rainbow Community Bank Ltd ( supra ).

25 See, https://www.designingbuildings.co.uk/wiki/Legal_and_equitable_assignment [accessed on 14th December 2023].

26 See, William Brandt's Sons & Co v Dunlop Rubber Co Ltd [1905] AC 454.

27 If it is incomplete, consideration may be required. Consideration will also be required where the assignment concerns some future chose as the agreement in such instance can only be a contract to assign and all contracts must be backed by consideration. See, Ben Electronic Co. (Nig) Ltd v. ATS & Sons & Ors (2013) LPELR-20870(CA) (pp 62 - 98 paras A - E).

28 The notice may be written or oral and the wording of the notice may be informal. A newspaper article may be a sufficient notice to the debtor. See, Lloyd v Banks (1868) LR 3. Ch App 488.

29 Re Knapman (1881) 18 Ch. D 300.

30 https://djetlawyer.com/assignment-of-choses-in-action/#:~:text=An%20assignment%20of%20a%20chose,legal%20(statutory)%20or%20equitable [accessed on 5 December 2023].

31 See, the rule in Dearle v Hall 3 Russell 1, 38 ER 475.

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 Emmanuel Bassey

As a general rule and based on the doctrine of privity a contract cannot confer rights or impose obligations on any person except the parties to the contract. Accordingly, a contract cannot be enforced by or against a person who is a stranger to it even if the contract is made for his benefit and purports to give him the right to sue or to make him liable upon it. The main reason for this is that it is the parties’ contract, and they are always free to vary or discharge it by agreement. The creation of a third party right would impede this freedom unless an agreement for such third party involvement has been made part of the agreement.

As with every general rule, there is always an exception. One of the exceptions to the doctrine of privity of contract arises in the assignment of choses in action where the owner of a contractual right can transfer same to a third party without the consent of the debtor (the counter-party to the contract), thereby enabling the third party to enforce the right against the debtor. The process of transfer of such a right is known as “assignment” and the types of property which are susceptible to this type of transfer are known as “choses in action.”

Choses in action is a legal expression used to describe all personal rights of property which can only be claimed or enforced by action and not by taking physical possession of them. They are also called “things in action” because they are things which a person is not possessed but has to bring an action in court in order to recover them. Choses in action may be legal or equitable. Legal choses in action are those which could historically only be enforced by an action at common law whilst equitable choses in action are choses in action which could only be enforced in the courts of equity- they arose out of property rights over which the Chancery Court formerly had exclusive jurisdiction. Examples of choses in action include debts, shares, negotiable instruments, policies of insurance, bills of lading, patents, copyrights, rights under trusts and legacies, benefit of a contract for sale of reversionary interest, rights to claim indefinite sums of money, as for compensation under Statute; damages for loss in which the assignee was the assignor’s insurer, a debt or benefit arising out of an existing contract, but payable at a future time and a claim for damages in tort. All these are intangible rights which cannot be physically possessed but only claimed or enforced by an action in court. They are in law permitted to be assigned by the holders (though they can neither be seen nor possessed) to third parties who would be able to enforce the rights against the debtors even though they were not parties to the original contract.

The term “assignment” refers to the act of transferring to another all or part of one’s property, interest, or rights.   The term denotes not only the act of transfer, but also the instrument by which it is effected. In Julius Berger (Nig) Plc & Anor v. Toki Rainbow Community Bank Ltd   the Court of Appeal held that “assignment means to give something to some body for their use or benefit. It also may mean to transfer right, property or title from the persons legally entitled to them to some body else for their benefit.”

The assignment of choses in action may be legal or equitable. Due to the vagaries of the historical evolution of law and equity, different considerations apply to the assignment of choses in action at law and in equity.

Historically, under common law contractual rights were hitherto not assignable without the consent of both contracting parties since they were things in action as opposed to things in possession. This common law rule stemmed from the difficulty of conceiving of transfer of an intangible, and the desire to avoid maintenance and champerty. The only methods of assigning contractual rights at common law were by novation and by procuring the debtor’s acknowledgment that he held for the assignee, both of which required the consent of the debtor, unless the assignment was done by the king or it involved the assignment of a mercantile chose in action like a negotiable instrument which are transferrable by mere delivery. Accordingly, legal choses in action could only be assigned at law with the consent of the debtor. The assignor was however, required to be joined as a party to any action to enforce the assignment (either as a plaintiff if he consented or as a defendant in the absence of consent) since there was no privity of contract between the debtor and the assignee.

Given the rigors of assignment of legal choses in action under the common law, the courts of equity developed more flexible requirements for the assignment of equitable choses in action. However, the most significant intervention was introduced by the enactment of the English Judicature Act of 1873 which introduced the concept of statutory assignment.

The enactment of the Judicature Act, 1873 (a statute of general application in Nigeria) created an exception to the doctrine of privity of contract by introducing the concept of trust of a chose in action in section 25(6) of the Act, which provides as follows:

6.1 The assignment must be absolute and not purport to be by way of charge only

An absolute transfer is a transfer of the whole not a part of the chose in action. The test to be applied in determining whether an assignment is absolute is whether the assignor has unconditionally transferred to the assignee for the time being, the sole right to the debt in question as against the debtor in which case the assignment is absolute. The fact that the assignee is to hold proceeds of the debts or the surplus proceeds beyond the stated amount, on trust for the assignor does not prevent the assignment from being absolute.

An assignment that purports to be by way of charge only is not an absolute assignment. The relevant test is to decide whether the assignment merely gives a right to the assignee to payment out of a particular fund by way of security rather than an unconditional transfer of the fund to the assignee. The judicial reasoning behind the requirement for an absolute assignment is that the debtor should not be put in doubt or jeopardy by the arrangements between the assignor and the assignee as to whom he is to discharge his obligations.

No particular form or mode is prescribed or required by law for a legal assignment as long as the assignor absolutely and unequivocally indicates the transfer of the benefit, interest or title to the assignee.

6.2 It must be in writing under the hand of the assignor

No particular mode or form is necessary as the writing can be informal, as for instance, a direction in writing by a creditor to his debtor to pay the assignee, handed to the assignee, may amount to an assignment but such a direction handed to the debtor may not by itself constitute an assignment unless there is evidence that the assignee has requested or consented to it. It is also the law that even if the debtor has the direction, it may not constitute more than authority to pay, and gives the assignee no rights unless the instructions can be said to amount to an irrevocable mandate to the debtor.

6.3 Express notice in writing thereof must be given to the debtor or trustee

This notice is not required to be in a separate document purposely prepared as a notice and described as such. What is needed is that information relative to the assignment shall be conveyed to the debtor, and that it shall be conveyed in writing. A written demand for payment sent by the assignee to the debtor has been held to be sufficient once the notice is unconditional and given to the debtor personally before the assignee commences his action. It has also been held that since a creditor can assign by directing his debtor to pay the assignee, a single written document would suffice to constitute both the Assignment as well as the notice envisaged by the Act. Furthermore, it is not necessary for the notice to the debtor to be given by the assignor or the assignee; it may be given by a third party.

• The assignee can sue the debtor in his own name instead of having to sue in the name of the assignor and perhaps to go to the Court of equity to compel his joinder in the action.
• Consideration is not required for the assignment.
• The consent of the assignee is not required for the assignment. However, where it is the liabilities or the burdens under a contract that are to be assigned to a debtor, the consent of the assignee is required.

An equitable assignment may be in writing or oral. It may operate by way of a charge only or be part of the debt or chose. If there is an equitable assignment of an equitable chose in action the assignment being absolute, then the assignee is entitled to sue in his own name.

Any words will suffice provided they are unambiguous to the effect that an identifiable debt has been made over by the creditor to some third person. No privity of contract or consideration is required for equitable assignment provided that the assignor has, at the material time, done all that he can to perfect the gift.

An equitable assignment is binding even without notice to the debtor. However, as a matter of practice, notice to the debtor is very important for three reasons:

• The giving of notice to the debtor has an effect on prior equities. The general rule as regards assignment of choses in action is that an assignee takes subject to the equities that already apply to the property in question. Thus, anyone who has a prior interest (legal or equitable) in an assigned chose is entitled to a higher priority than that of the assignee. The reason for this is that the assignee cannot acquire a better title than that of the assignor. What he essentially gains by virtue of the assignment is a right to continue in the stead of the assignor in respect of that chose and nothing better.Claims of equities that arise after notice of the assignment has been given to the debtor would not affect the assignee, except where the claim is very closely related to the original transaction upon which the chose came into existence. The rule that the assignee takes subject to equities will not apply where the trustee is estopped, either by conduct or deed, from setting up equities against the assignee. It would not also apply where the agreement occasioning the original transaction includes a clause that the assignees of the assignor would take free from all equities.
• The date of notice establishes the order of priority as between successive assignees. Thus, where there are two or more assignees of the same chose in action, the first to give notice has priority over the other assignees even if they were first in time.

Assignment of choses in action provides a veritable avenue for the exchange of contractual rights, especially when the assignor does not have the wherewithal to enforce the right in court. This creates a win-win situation for the assignor and the assignee, as the assignor is immediately able to receive value for his rights and the assignee is able to enforce the right to receive whatever benefit he has contracted for whilst the debtor’s position is not adversely affected. The parties, however, need to understand the applicable principles so that they would know the extent of any rights that they acquire in any given transaction.

______________________________

For further information on this article and area of law, please contact Emmanuel Bassey  at: S. P. A. Ajibade & Co., Lagos by Telephone (+234 1 472 9890), Fax (+234 1 4605092) Mobile (+234.703.805.9736, +234.815.088.2839) Email: [email protected] www.spaajibade.com

• Emmanuel Abasiubong Bassey, Senior Associate in the Dispute Resolution Department of S.P.A. Ajibade & Co., Lagos, Nigeria.
• Makwe v. Nwukor & Anor (2001) LPELR-1830(SC) (pp 25 – 25 paras D – E). See, Ben Electronic Co. (Nig) Ltd v. ATS & Sons & Ors. (2013) LPELR-20870(CA) (pp 62 – 98 paras A – E). It was however, held that the benefit of a contract is only assignable in cases where it can make no difference to the person on whom the obligation lies to which of two persons he is to discharge it. See, Tolhurst v. Associated Portland Cement Manufacturers Ltd (1902) 2 K.B. 660 at 668, (1903) A.C. 414 cited in Julius Berger (Nig) Plc & Anor v. Toki Rainbow Community Bank Ltd (2009) LPELR-4381(CA) (pp 24 – 25 paras E – C).
• I. E. Sagay, Nigerian Law of Contract (first published 1985, 2nd Edn, Spectrum Books Limited, Ibadan, 2000) 516.
• See, https://mcmahonsolicitors.ie/choses-in-action/ [accessed on 14th December 2023.] Supra.
• See, Ben Electronic Co. (Nig) Ltd v. ATS & Sons & Ors (supra).
• See, FCMB v. Essien (2022) LPELR-58699(CA) (pp 6 – 6 paras E – F).
• See, FCMB v. Essien (supra).
• Julius Berger (Nig) Plc & Anor v. Toki Rainbow Community Bank Ltd (2009) LPELR-4381(CA) (pp 24 – 25 paras E – C).
• The following choses are however not assignable: (1) Salaries of public officials. This is because it is perceived that if allowed to assign their salaries, they may deprive themselves of their means of sustenance and thereby impair the efficiency which is most desirable for the public service; (2) Alimony- because the money is meant for the maintenance of the spouse and (3) Rights arising out of a contract for personal service.
• Maintenance occurs when a third-party provides support for litigation without a just cause, by providing, for example, financial assistance. Champerty is an aggravated form of maintenance, where a third-party pays some or all of the litigation costs in return for a share of the proceeds.
• (36 & 37 Vict.) CHAPTER 66.
• In Nigeria, a statute of general application refers to refers to statutes which were in force in England on the 1st of January, 1900. They were to be applied by the courts in Nigeria as far as local circumstances permit. However, the Western Region is now exempted by virtue of Law of England (Application) Law of 1959. The West African Court of Appeal stated in Young v. Abina that it was not necessary for the statute to be in force in all of the United Kingdom, but it only had to be in force in England. See, https://www.learnnigerianlaw.com/learn/legal-system/englishlaw accessed on 12th December 2023.
• Section 25 (6) of the Judicature Act i873 which has now been repealed and replaced substantially by Section 136 of the English Law of Property Act, 1925, in England.
• See, Ben Electronic Co. (Nig) Ltd v. ATS & Sons & Ors. (supra). It has been held that the benefit of a contract is only assignable in cases where it can make no difference to the person on whom the obligation lies to which of two persons he is to discharge it. See, Tolhurst v. Associated Portland Cement Manufacturers Ltd (1902) 2 K.B. 660 at 668, (1903) A.C. 414 cited in Julius Berger (Nig) Plc & Anor v. Toki Rainbow Community Bank Ltd (2009) LPELR-4381(CA) (pp 24 – 25 paras E – C).
• See, https://www.designingbuildings.co.uk/wiki/Legal_and_equitable_assignment [accessed on 14th December 2023].
• See, Julius Berger (Nig) Plc & Anor v. Toki Rainbow Community Bank Ltd (2009) LPELR-4381(CA) (pp 25 – 26 paras D – D).
• See, Bateman v. Hunt, 20 T. L. R. 628.
• See, Julius Berger (Nig) Plc & Anor v. Toki Rainbow Community Bank Ltd (supra).
• See, William Brandt’s Sons & Co v Dunlop Rubber Co Ltd [1905] AC 454.
• If it is incomplete, consideration may be required. Consideration will also be required where the assignment concerns some future chose as the agreement in such instance can only be a contract to assign and all contracts must be backed by consideration. See, Ben Electronic Co. (Nig) Ltd v. ATS & Sons & Ors (2013) LPELR-20870(CA) (pp 62 – 98 paras A – E).
• The notice may be written or oral and the wording of the notice may be informal. A newspaper article may be a sufficient notice to the debtor. See, Lloyd v Banks (1868) LR 3. Ch App 488.
• Re Knapman (1881) 18 Ch. D 300.
• https://djetlawyer.com/assignment-of-choses-in-action/#:~:text=An%20assignment%20of%20a%20chose,legal%20(statutory)%20or%20equitable [accessed on 5 December 2023].
• See, the rule in Dearle v Hall 3 Russell 1, 38 ER 475.

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Assignment of Choses in Action

Property generally may be realty (real) or personalty (personal). Realty are characterized by geographical fixity(land) while personalty are generally mobile.

Personalty is also classified into tangible/corporeal and intangible/incorporeal. The former is capable of physical handling/possession/manipulation/enjoyment while the latter is incapable of any of these.

Incorporeal property is also called a chose in action which has been defined as a legal expression used to describe all personal rights of property which can only be claimed or enforced by action (in a court) and not by taking physical possession.

A chose generally is a thing capable of being owned. Choses in action may be legal or equitable. Legal choses in action are rights which were enforceable or recoverable only by an action at Common law. This category of choses includes debts, benefits under a contract, insurance policies, copyrights, patents etc.

Equitable choses on the other hand are rights over property which were only enforceable/recoverable/cognizable by the courts of Chancery. It could only be recovered by a suit in Equity and the rights under this category include interests of a beneficiary in a Trust, a legacy/reversionary interest under a will etc.

Choses in action may also be in respect of already existing things/property or things/property to be acquired at a future date but which are not yet in possession. The chose in action may be property in itself and it may also be a propriety right over property.

Assignment is the transfer of something from one person to another such that the assignee obtains rights of a nature that were hitherto exercisable only by the assignor. An assignment of a chose is thus the transfer of a chose in action from the assignor to the assignee such that the assignee obtains and becomes entitled to enjoy rights in respect of that chose, which were hitherto exclusively enjoyed by the assignor.

Assignment may be legal (statutory) or equitable.

Assignment and Novation

An assignment is quite distinct from a novation. Novation is essentially a legal device by which parties to a contract may legally vary/shift their obligations under the contract to third parties. Thus, A can agree with B, his creditor, that C, who owes him money, will pay that debt to B in full satisfaction of his own (A’s) debt.

Novation is however fundamentally different from assignment in three material aspects:

• The consent of the parties is sine qua non since the original contract is rescinded by the novation. There must thus be consensus ad idem. There can be no novation otherwise. This is contrary to the case in assignment where there only need be communication to the assignee, his consent and that of the trustee of the liability are immaterial.
• The original debt in novation must be totally extinguished under the new arrangement.

There is no such requirement for assignment to be valid.

• For novation to be valid, there must be consideration in all cases as it is essentially a new contract. The requirement for consideration in assignment is much more relaxed.

Assignment and Equities

The general rule as regards assignment of choses in action is that an assignee takes, subject to the equities thar already apply to the chose in action (property) in question. Thus, anyone who has an interest (legal or equitable) in an assigned chose is entitled to a higher priority than that of the assignee.

The logic here is based on a recognition that the assignee cannot acquire a better title than that of the assignor. What he essentially gains by virtue of the assignment is a right to continue in the stead of the assignor in respect of that chose and nothing better.

In Re Knapman (1881) 18 Ch. D 300 the beneficiaries of a will brought an action against the executor seeking to revoke the probate. While the matter was in court, these beneficiaries assigned the right under the will to someone else.

Their action subsequently failed in court, the court ruled that the executor had a right to set off the costs of the suit against the estate. As such, since the right to this had already been assigned, the assignee has to settle this cost since he was assigned a property that had a pre-existing liability.

Claims of equities that arise after notice of the assignment has been given to the trustee would not affect the assignee however, except where the claim is very closely related to the original transaction upon which the chose came into existence.

The rule that the assignee takes subject to equities will not apply where the trustee is estopped, either by conduct or deed, from setting up equities against the assignee. It would not also apply where the agreement occasioning the original transaction includes a clause that the assignees of the assignor would take free from all equities.

Historically, assignment of choses in action was largely unrecognized at Common law. There was the fear that allowing such assignment would bring about Maintenance and even cases of Champerty as well as the risk of encouraging a litany of contentious matters on the same res.

Maintenance arises where a person who has no legal interest in a matter provides assistance by money or otherwise to a party to the suit while Champerty marries the foregoing with the prospect of reward out of the possible spoils of the suit.

Thus, no debt could be assigned at Common law unless the debtor specifically agreed to the assignment. The only exceptions allowed by Common law were in respect of choses in action assigned by or to the King and assignment of negotiable instruments in order to promote trade.

Equity has however always recognized the assignment of choses in action, both equitable and legal. It would not however allow the assignment of bare rights without accompanying interest in property. This was to avoid, as in the case of the Common law, situations that encourage Maintenance.

Assignability

Not all choses in action are assignable. The courts would not give effect to such assignments either on grounds of public policy or on account of the nature of the subject matter of the assignment.

Choses in action that are not assignable include:

• Salaries of public officials. This is because it is perceived that if allowed to assign their salaries, they may deprive themselves of their means of sustenance and thereby impair the efficiency which is most desirable for the public service.
• Alimony is not assignable on much the same grounds as salaries of public officials as the money is meant for the maintenance of the spouse.
• Rights arising out of a contract of a personal nature i.e. contracts that require personal service like employment.
• Expectancies (future choses) are not assignable at Common law based on the maxim: Nemo dat quod non habet. They are assignable in Equity although, such assignment must be for value.

Equitable Assignment

An equitable assignment is of a flexible nature. This flexibility makes it quite distinct from legal assignments as they do not require all of the formality required under the law. It may be in respect of a legal or equitable chose. Thus, there may be an equitable assignment of an equitable chose or an equitable assignment of a legal chose.

While there is no strict formality required for equitable assignments, certain criteria are instructive as to whether it would be considered valid or not.

For an equitable assignment to be considered as having been effected, there must be a clear intent to assign. While Equity does not require that the assignment be in writing or made in any particular format, there must be a clearly deducible intent to assign on the part of the assignor.

The intent to assign here will be construed from the words used and the particular circumstances of the case. If what is construed is a mere mandate/authority to hold onto certain property, no intent to assign may be ascribed by the court.

The position that Equity does not require writing for equitable assignments has however been affected by S. 9 of the Statute of Frauds and S. 78(1)(c) of the Property and Conveyancing Law which require that the assignment of any equitable interest or trust must be in writing.

The assignment is also required to be communicated to the assignee. Although, the assignee may still take in certain instances even without communication, subject to the right of the assignee to repudiate the transfer when he becomes aware of it.

The particular chose intended to be assigned must be identified. It is insufficient to give a vague representation of what is sought to be assigned. Such vagueness may impair the court’s construction of an intent to assign in such circumstance.

Consideration in equitable assignment depends on the circumstance. Where the assignment is complete in the sense that there is nothing left for the assignor to do to perfect the assignee’s title, there would be no need for consideration.

If it is incomplete though, consideration may be required. Consideration will also be required where the assignment concerns some future chose as the agreement in such instance can only be a contract to assign and all contracts must be backed by consideration.

No consideration is however required for assignment of existing choses.

There is no real requirement for notice of the equitable assignment to be given to the trustee of the liability. Notice is however useful to the extent that it puts the trustee on guard as to the change of rights affecting the chose and may prevent him from settling in favour of the assignor instead of the assignee.

It also makes the trustee liable to the assignee where he settles in favour of the assignor in spite of the notice given to him. Again, while the assignee generally takes subject to any prior equities affecting the chose, giving notice ensures that he would not be affected by any subsequent equities.

Most importantly, notice allows the assignee to establish the priority of his interest in consequence of the rule in DEARLE v HALL.

An equitable assignment of a chose in action has bearing on the manner in which the rights can be enforced in a court of law. The effect here is largely dependent on whether the chose in question is a legal or equitable chose and if the chose was absolutely assigned or not.

Where the assignment concerns a legal chose, the assignee cannot assert his title over the property in his own name. He must join the name of the assignor either as co-plaintiff, where he agrees, or as a defendant. Where the chose is equitable though, the assignee can sue in his own name.

An assignment is absolute when the assignor transfers his whole interest in the chose to the assignee. It is however non-absolute where it is made subject to some condition at the happening of which it would become inoperable or where only a charge is made on the chose, in favour of the assignee.

In this instance, only a part of the assignor’s interest is transferred. The effect of this is that in situations where the transfer was absolute, the assignee would be able to sue in his own name. Where it is not absolute however, he must join the assignor before he can enforce his rights over the chose.

Where the chose is legal though, it is immaterial whether it is absolute or not, the assignee must join the assignor.

Legal Assignment

The Common law rule against assignment of choses in action was only lifted in 1875 and this was via the provision of the Judicature Acts, particularly S. 25(6) . This provision is impari materia with S. 150(1) Property and Conveyancing Law .

The purport of those provisions is that there can be absolute assignments by writing of any debt or other legal thing in action when express notice in writing has been given to the trustee of the liability. Also, it shall be effectual to transfer the legal right to sue in respect of such thing, along with the legal and other remedies in respect of it and the power to give a good discharge for the chose without the assignor’s permission.

The provisions clearly contain ingredients that would make a legal assignment valid and these include the following:

• The assignment must be in writing and signed by the assignor.
• It must be in respect of some existing debt or other legal thing in action and this includes equitable choses in action.
• It must be absolute.
• There must be an express notice in writing given to the debtor, trustee, or other person from whom the assignor would have been entitled to receive the debt or claim the thing in action.

The assignment takes effect from the date that notice is given. Failure to give notice at all or failure to give it in writing or failure to even execute the writing in the first place will not invalidate the assignment.

Rather, it becomes an equitable assignment instead of a legal one. Further, there is no requirement for consideration here.

The position at Common law before the Act amended it was that the assignee had no right independent of the assignor’s and was obligated to sue in the assignor’s name if he wanted to enforce his rights over the chose.

The Acts have however changed this and the assignee no longer needs to sue in the name of the assignor. He can sue all by himself.

2 thoughts on “ Assignment of Choses in Action ”

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Assignment of choses in action.

As a rule, choses in action are your rights that you must claim. They are not in your actual possession to benefit from them, rather you may lose. To simplify, your money in your hand is a chose in possession, whereas your money in the bank is a chose in action wherein you need an action to possess. Based on this, it was claimed that choses in action are not eligible for assignment. This assumption continues for long time, however, the situation has been changed by law and accordingly, choses in action could legally be assigned. To begin this legal process, the power to assign was first handled by Statute giving insurance policy holders the right to assign the policy, which is a chose in action not possession. The law provides that, this to happen in instances of, an absolute assignment by writing from the assignor of any debt or other legal thing in action (chose), of which express notice in writing has been given to the debtor, trustee or other person from whom the assignor would have been entitled to claim such debt or thing in action (chose). Moreover, it is effectual in law to pass and transfer from the date of such notice, the legal right to such debt or thing in action, all legal and other remedies from the same and the power to give a good discharge for the same without the concurrence of the assignor. This is effectual in law provided that, if the debtor, trustee or other person liable in respect of debt or thing in action (chose) has notice, that the assignment is disputed by the assignor or any person or under him or of any other opposing or conflicting claims to such debt or action. He may if he thinks fit, either call upon the persons making claim or interplead concerning the same, or pay the debt or thing into Court. However, the assignment must be absolute, must be in writing under the hand of the assignor, consideration is not necessary, express notice in writing must be given to the debtor and the assignment is subject to existing equities. Based on above legal parameters and requirements, choses in action are eligible for assignment. In other words you can either claim your chose in action directly or opt for assignment to benefit from.

Dr. AbdelGadir Warsama LEGAL COUNSEL Email: [email protected]

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Conditions For Assignment Of Burden Or Benefit of Debt.

Daily Law Tips (Tip 766) by Onyekachi Umah, Esq., LL.M, ACIArb(UK)

Introduction: Debt is generally any amount of money owed. Managing debt and debtors can be frustrating, especially in a country with poor access to justice and no dependable database. Both the burden of a debtor to repay debt and the benefit of a creditor to recover debt can be assigned and transferred to a third party. However, there are conditions that must be observed for an assignment of debt to be valid. The conditions and are considered below.

Transfer of Burden or Benefit of Debt: In every debt, there must be at least a debtor and a creditor. While the debtor has an obligation to repay debt, a creditor has a right to demand and recover debt. There could be transactions seeking to transfer and assign the responsibilities of a debtor or creditor. For such assignment to be lawful and effective, there are basic conditions that must be fulfilled, according to the Supreme Court of Nigeria.

1. The Supreme Court of Nigeria in the case of FERDINAND GEORGE v. UNITED BANK FOR AFRICA LIMITED (1972) LPELR-1321(SC) , where the court held that; “Obviously, where the burden of a debt is being assigned, the creditor must consent or the assignment could be used as a simple means of avoiding liability. When the benefit of a debt is assigned the debtor does not need to consent. He still owes the money which he previously borrowed, and so long as he knows whom to pay in order to get an effective receipt and discharge he has no cause to be consulted over the assignment.” Per FATAYI-WILLIAMS ,J.S.C (Pp. 9 paras. A)

2. The Court of Appeal in the case of JULIUS BERGER NIGERIA PLC & ANOR v. TOKI RAINBOW COMMUNITY BANK LTD (2009) LPELR-4381(CA) “Under the common law, a debt or other legal thing in action includes the benefit of a contract or a debt arising out of contract from which payment was to be made at a future date. Such debt is capable of being assigned under section 136 of the Law of property Act 1925. See BRICE V. BANNISTER (178) 3 Q. B.D. 569, JAMES V. HUMPHREYS (1908) 1 KB. 10, CONTRAST LAW V. COBURN (1972) 1 WLR 1238. Furthermore is was held that the benefit of a contract is only assignable in cases where it can make no difference to the person on whom the obligation lies to which of two persons he is to discharge it. TOLTURST V. ASSOC PORTLAND CEMENT MANUFACTURERS LTD (1902) 2 K.B. 660 at 668, (1903) A.C. 414. A party to a contract can in equity also assign a contractual right in one of two ways (a) he can inform the assignee that he transfers the chose to him or (b) he can instruct the debtor to discharges the Obligation by payment to or performance for, the assignee. Thus an agreement by traders or merchants with a Bank that payment for goods sold by them should be remitted direct by the purchasers to the Bank has been held to, constitute a valid equitable assignment of the amount to the Bank. BRANDTS SONS & CO. V. DUNLOP RUBBERCO. (1905) A.C. 454. Generally however, a mere direction by a creditor to his debtor to pay money to a third party is not necessarily an assignment unless the instructions can be said in their context text, to amount to an irrevocable mandate to the debtor. See CURRAN V. NEWPARK UNEMAS LTD (1957) 1 ALL E.R. 295, BRITISH EAGLE INT’L AIRLINES LTD V. CIE NATIONAL AIR FRANCE (1973) 1 LIOYD’S REP.414 AT 427. Another principle of the common law on assignment in that an assignment made by letter is complete as soon as the letter is posted to the assignee as was held in the case of ALEXANDER V. STENHARDTWAKER & CO. 0903) 2 K.B. 208 The above general positions of the common law on assignment are to guilde a determination of the issue. whether indeed, fact and law, there was an assignment of the benefits of the contracts between the company and the 1st Appellant to the Respondent.” Per MOHAMMED LAWAL GARBA ,JCA (Pp. 27-29, paras. C-B)

3. The Court of Appeal in the case of JULIUS BERGER NIGERIA PLC & ANOR v. TOKI RAINBOW COMMUNITY BANK LTD (2009) LPELR-4381(CA) “The question I now ask is what in law are the essential requirements which make an assignment of such benefits, interests or title to property effective? Speaking generally, they include:-(1) ownership of or entitlement to the benefits, interest, rights or title to property by the assignor; (2) the absolute transfer in writing of such benefits, interests, rights or title to property to person/named therein; (3) Where, as in the present appeal, the benefits, rights and interests are in possession or custody of 3rd party, there is the requirement that the assignor should notify that 3rd party in writing of the assignment. See Chitty on Contracts Vol. 1 Paragraph 19 – 007 at page 1166, Halbury’s Laws of England, 4th Edition, volume 6 paragraphs 12 at page 9. It is however to be noted that no particular form or mode is prescribed or required by law for a legal assignment as long as the assignor absolutely and unequivocally indicates the transfer of the benefit, interest or title to the assignee. Once the above requirements are met, an assignment will be effective in law and the assignee would be entitled to the subject of the transfer and a claim thereto.” Per GARBA ,J.C.A ( Pp. 25-26, para. D )

4. The Court of Appeal in the case of BEN ELECTRONIC CO. (NIG) LTD v. ATS & SONS & ORS (2013) LPELR-20870(CA) “It is not in doubt that Professor Sagay in his text Nigerian Law of Contract, 2nd Edition, Ibadan Spectrum Books Ltd. 2000 at page 516 paragraph 9, had supported the views expressed by the learned Counsel to the Appellant that in certain circumstances the owner of a contractual right can transfer same to a third party without the consent of the debtor, thereby enabling the third party to enforce the right against the debtor or obligator. The learned Author following English authorities like Torkington v. Magee (1902) 2 K.B. 42 at page 430, other texts like “Cheshire & Fifoot on Equity 10th Edition” (pages 455 – 475) and Jegede’s “Principles of Equity” pages 145 – 184, also added that the process of transfer of such a right is known as “Assignment” and that the types of property which are susceptible to this type of transfer are known as “Choses in action.”

“Section 25(6) of Judicature Act now replicated in Section 136 of the Law of Property Act 1925 provides as follows: (1) Any absolute assignment by writing under the hand of the assignor (not purporting to be by way of charge only) of any debt or other legal thing in action, of which express notice in writing has been given to the debtor, trustee or other person from whom the assignor would have been entitled to claim such debt or thing in action, is effectual in law (subject to equities having priority over the right of the assignee) to pass and transfer from the date of such notice;- (a) The legal right to such debt or thing in action (b) All legal and other remedies for the same and (c) The power to give a good discharge for the same concurrence of the assignor; Provided that if the debtor, trustee or other person liable in respect of such debt or thing in action has notice:- i. That the assignment is disputed by the Assignor or any person under him or; ii. Of any other opposing or conflicting claim to such debt or thing in action, he may if he thinks fit either call upon the person making claim hereto to inter plead concerning the same, or pay the debt or other in action in Court.”

Conclusion: Debt is payable, even where the original creditor appoints another person as its representative or replacement. The consent of a debtor to such arrangement is not needed. However, a debtor cannot transfer his obligation to repay debt to a third party, except with the consent of his creditor. Any such assignment by a debtor without the approval of his creditor is deemed as a plan to delay/evade debt. Although no particular writing style or form is approved for assignment of debt, an assignment of burden of debt or benefit of debt should be clear and ambiguous at all times.

My authorities, are:

1. Sections 1, 2, 3, 4, 5 and 6 of the Constitution of the Federal Republic of Nigeria, 1999. 2. Judgement of the Supreme Court of Nigeria in the case of FERDINAND GEORGE v. UNITED BANK FOR AFRICA LIMITED (1972) LPELR-1321(SC) 3. Judgment of the Court of Appeal in the case of JULIUS BERGER NIGERIA PLC & ANOR v. TOKI RAINBOW COMMUNITY BANK LTD (2009) LPELR-4381(CA) 4. Judgment of the Court of Appeal in the case of BEN ELECTRONIC CO. (NIG) LTD v. ATS & SONS & ORS (2013) LPELR-20870(CA) 5. Onyekachi Umah, “Creditors, Debtors And The Covid-19 Lockdown?” (LearnNigerianLaws.com, 21 April 2020) < https://learnnigerianlaws.com/creditors-debtors-and-the-covid-19-lockdown-daily-law-tips-tip-552-by-onyekachi-umah-esq-llm-aciarbuk/ > accessed 28 March 2021 6. Onyekachi Umah, “Owing Debts And Refusing To Pay Is Not An Offence In Nigeria” (LearnNigerianLaws.com, 14 December 2019) < https://learnnigerianlaws.com/owing-debts-and-refusing-to-pay-is-not-an-offence-in-nigeria-daily-law-tips-tip-478-by-onyekachi-umah-esq-llm-aciarb-uk/ > accessed 28 March 2021 7. Onyekachi Umah, “The Supreme Court Has Warned Efcc And Police Against Recovering Debts And Investigating Disputes From Civil Transactions” (LearnNigerianLaws.com, 26 October 2019) < https://learnnigerianlaws.com/the-supreme-court-has-warned-efcc-and-police-against-recovering-debts-and-investigating-disputes-from-civil-transactions-daily-law-tips-tip-444-by-onyekachi-umah-esq-llm-aciarb-uk/ > accessed 28 March 2021 8. Onyekachi Umah, “When, Why And How Can A Guarantor/Surety Be Held Liable For Debt Guaranteed” (LearnNigerianLaws.com, 25 July 2019) < https://learnnigerianlaws.com/when-why-and-how-can-a-guarantor-surety-be-held-liable-for-debt-guaranteed-daily-law-tips-tip-380-by-onyekachi-umah-esq-llm-aciarb-uk/ > accessed 28 March 2021 9. Onyekachi Umah, “How To Be Exempted From Electricity Disconnection In Any Part Of Nigeria Even When Owing Debt For Consumed Electricity.” (LearnNigerianLaws.com, 29 June 2019) < https://learnnigerianlaws.com/how-to-be-exempted-from-electricity-disconnection-in-any-part-of-nigeria-even-when-owing-debt-for-consumed-electricity-daily-law-tips-tip-361-by-onyekachi-umah-esq-llm-aciarb-uk/ > accessed 28 March 2019 10. Onyekachi Umah, “You Cannot Be Arrested For Breach Of Contract/Refusal To Pay Debt” (LearnNigerianLaws.com, 15 October 2018) < https://learnnigerianlaws.com/daily-law-tips-by-onyekachi-umah-esq-tip-205-you-cannot-be-arrested-for-breach-of-contract-refusal-to-pay-debt/ > accessed 28 March 2021 11. Onyekachi Umah, “It Is An Offence For Hospitals/Creditors To Detain Patients/Debtors For Debts” (LearnNigerianLaws.com, 26 July 2018) < https://learnnigerianlaws.com/daily-law-tips-by-onyekachi-umah-esq-tip-150-it-is-an-offence-for-hospitals-creditors-to-detain-patients-debtors-for-debts/ > accessed 28 March 2021 12. Onyekachi Umah, “EFCC Cannot Recover Debts” (LearnNigerianLaws.com, 25 July 2018) < https://learnnigerianlaws.com/daily-law-tips-by-onyekachi-umah-esq-tip-149-efcc-cannot-recover-debts/ > accessed 28 March 2021 13. Onyekachi Umah, “It Is Not a Crime to Be a Debtor In Nigeria” (LearnNigerianLaws.com, 20 June 2018) <https://learnnigerianlaws.com/daily-law-tips-by-onyekachi-umah-esq-tip-124-it-is-not-a-crime-to-be-a-debtor-in-nigeria/> accessed 28 March 2021 14. Onyekachi Umah, “Nigerian Police Cannot Be Used For or Be Part for Debt Recovery” (LearnNigerianLaws.com, 28 May 2018) < https://learnnigerianlaws.com/daily-law-tips-by-onyekachi-umah-esq-tip-110-nigerian-police-cannot-be-used-for-or-be-part-for-debt-recovery/ > accessed 28 March 2021 15. Onyekachi Umah, “Tips On Recovery of Debt’ (LearnNigerianLaws.com, 10 March 2016) <https://learnnigerianlaws.com/tips-on-recovery-of-debt/> accessed 28 March 2021 16. Onyekachi Umah, “How to Recover Property Wrongly Seized by Court” (LearnNigerianLaws.com, 9 March 2021) < https://learnnigerianlaws.com/how-to-recover-property-wrongly-seized-by-court/ > accessed 28 March 2021 17. Onyekachi Umah, “Should Landlord Stop Rent-Owing Tenants from Moving Out?” (LearnNigerianLaws.com, 26 August 2020) < https://learnnigerianlaws.com/should-landlord-stop-rent-owing-tenants-from-moving-out/ > accessed 28 March 2021 18. Onyekachi Umah, “Should A Landlord Remove Roof Of A Tenant For Failure To Pay Rent/Pack Out?” (LearnNigerianLaws.com, 3 August 2020) < https://learnnigerianlaws.com/should-a-landlord-remove-roof-of-a-tenant-for-failure-to-pay-rent-pack-out-daily-law-tips-tip-624-by-onyekachi-umah-esq-ll-m-aciarbuk/ > accessed 28 March 2021 19. Onyekachi Umah, “Should A Landlord Lock Gates/Doors Of A Tenant For Failure To Pay Rent/Pack Out?” (LearnNigerianLaws.com, 29 July 2020) < https://learnnigerianlaws.com/should-a-landlord-lock-gates-doors-of-a-tenant-for-failure-to-pay-rent-pack-out-daily-law-tips-tip-620-by-onyekachi-umah-esq-ll-m-aciarbuk/ > accessed 28 March 2021 20. Onyekachi Umah, “Should A Landlord Cut-Off Tenant From Water/Electricity Supply For Failure To Pay Rent/Pack Out?” (LearnNigerianLaws.com, 17 July 2020) < https://learnnigerianlaws.com/should-a-landlord-cut-off-tenant-from-water-electricity-supply-for-failure-to-pay-rent-pack-out-daily-law-tips-tip-612-by-onyekachi-umah-esq-ll-m-aciarbuk/ > accessed 23 March 2021 21. Onyekachi Umah, “Does Police Have Powers To Settle Civil Disputes In Nigeria?” (LearnNigerianLaws.com, 13 May 2020) <Does Police Have Powers To Settle Civil Disputes In Nigeria?> accessed 28 March 2021 22. Onyekachi Umah, “A Guarantor/ Surety And A Witness Are Not Same” (LearnNigeriansLaws.com, 12 May 2020) < https://learnnigerianlaws.com/a-guarantor-surety-and-a-witness-are-not-same-daily-law-tips-tip-567-by-onyekachi-umah-esq-llm-aciarbuk/ > accessed 28 March 2021 23. Onyekachi Umah, “Minimum Period For Defence Of Undefended List Case In Abuja” (LearnNigerianLaws.com, 25 February 2020) < https://learnnigerianlaws.com/minimum-period-for-defence-of-undefended-list-case-in-abuja-daily-law-tips-tip-512-by-onyekachi-umah-esq-llm-aciarbuk/ > accessed 28 March 2021 24. Onyekachi Umah, “Bounced Or Dud Cheque And Its Legal Consequence In Nigeria.” (LearnNigerianLaws.com, 5 March 2016) < https://learnnigerianlaws.com/bounced-or-dud-cheque-and-its-legal-consequence/ > accessed 28 March 2021

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• Table of legislation
• 1. An introduction to commercial law
• 2. Basic concepts of personal property
• 3. Bailment
• 4. Introduction
• 5. Creation of agency, and the authority of the agent
• 6. Relations with third parties
• 7. Relations between principal and agent
• 8. Introduction and definitions
• 9. Passing of the property in the goods as between seller and buyer
• 10. Transfer of title
• 11. Seller’s obligations as to quality
• 12. Performance of the contract
• 13. Remedies of the seller
• 14. Remedies of the buyer
• 15. International sales
• 16. Modern payment systems
• 17. Payment cards and electronic money
• 18. Negotiable instruments
• 19. Bills of exchange
• 20. Cheques and miscellaneous payment instruments
• 21. The financing of international trade
• 22. Assignment of choses in action
• 23. Receivables financing
• 24. Introduction
• 25. Possessory security
• 26. Non-possessory security
• 27. Insurance
• 28. Insolvency

p. 787 22. Assignment of choses in action

• D Fox , D Fox Professor of Common Law, University of Edinburgh
• RJC Munday , RJC Munday Reader Emeritus in Law, University of Cambridge
• B Soyer , B Soyer Professor of Commercial and Maritime Law, Institute of International Shipping and Trade Law, Swansea University
• AM Tettenborn AM Tettenborn Chair in Law, Swansea University
•  and  PG Turner PG Turner Visiting Senior Fellow of the Melbourne Law School
• https://doi.org/10.1093/he/9780198842149.003.0022
• Published in print: 13 July 2020
• Published online: September 2020

This chapter deals with the general law of assignment of choses in action. Beginning with the historically based difference between equitable and statutory assignment, it then explains what ‘chose in action’ and ‘assignment’ are before discussing the requirement that there be an existing and assignable chose in action or right as well as the requirement that a person who holds an existing assignable chose in action intends to assign it. It also examines whether and when a rule of legal formality requires writing to be made; whether and when notice of the assignment is required; and obstacles to the enforcement of an assigned chose in action.

• chose in action
• law of assignment
• legal formality
• enforcement

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• Foreword to The Third Edition
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• Part III.01

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• United Nations

Treaty Establishing the European Community (as amended by other Treaties) (European Union) [2006] OJ 321 E/37 (Date signed: 25th March 1957)

• External Link

Part II The Transfer of Intangible Property, 13 Equitable Assignment of Choses in Action

From: the law of assignment (3rd edition), marcus smith, nico leslie.

This chapter studies the requirements that are necessary for an effective assignment of choses in action. In order to effect the assignment or a chose in action: the assignor must have manifested an intention to transfer the chose; the thing being assigned must be a chose in action, in present existence, certain or capable of being ascertained; the identity of the assignee must be clear; and the appropriate forms and formalities must have been satisfied. These requirements apply both to legal and equitable assignments. However, since legal assignments can only be affected by statute, the forms and formalities required for a legal assignment are those set out in the relevant legislation, and addressed elsewhere.

• Browse Study Materials

Law of Equity and Trusts

LAW OF EQUITY AND TRUSTS PART I AND II

TABLE OF CONTENTS

LAW OF EQUITY PART 1

DEFINITION OF EQUITY.

NATURE, ORIGIN AND RECEPTION OF EQUITY.

THE MAXIMS AND PRINCIPLES OF EQUITY

NATURE OF EQUITABLE INTEREST AND THE DOCTRINE OF NOTICE.9

EQUITABLE INTEREST AND LEGAL ESTATES

THE DOCTRINE OF NOTICE.

PARTICULAR EQUITABLE INTERESTS.

ASSIGNMENT OF CHOSES IN ACTION.

DISTINCTION BETWEEN NOVATION AND ASSIGNMENT.

THE DOCTRINE OF CONVERSION

THE DOCTRINE OF SATISFACTION.

THE DOCTRINE OF PERFORMANCE

THE DOCTRINE OF ELECTION.

THE REMEDY OF INJUNCTION.

SPECIFIC PERFORMANCE.

THE REMEDY OF RESCISSION.

RECTIFICATION.

DEFENCES AVAILABLE TO EQUITABLE REMEDIES.

EQUITY PART II/LAW OF TRUSTS.

DEFINITION OF TRUST.

TRUST DISTINGUISHED FROM OTHER LEGAL CONCEPTIONS.

CLASSIFICATION OF TRUST

EXPRESS PRIVATE TRUST

ESSENTIALS OF A TRUST… THE THREE CERTAINTIES.

COMPLETELY AND INCOMPLETELY CONSTITUTED TRUST

TRUST OF IMPERFECT OBLIGATION.

RESULTING AND CONSTRUCTIVE TRUSTS.

CHARITABLE TRUSTS.

TRUSTEES. APPOINTMENT, QUALIFICATION, DUTIES, POWERS, DETERMINATION, REMEDIES FOR BREACH OF TRUST, ETC.

THE EQUITABLE REMEDY OF TRACING.

PERPETUITIES AND ACCUMULATION.

Solutions, V. (2021). Law of Equity and Trusts. Afribary . Retrieved from https://afribary.com/works/law-of-equity-and-trusts-isochukwu

Solutions, Vite "Law of Equity and Trusts" Afribary . Afribary, 06 Jan. 2021, https://afribary.com/works/law-of-equity-and-trusts-isochukwu. Accessed 06 Apr. 2024.

Solutions, Vite . "Law of Equity and Trusts". Afribary , Afribary, 06 Jan. 2021. Web. 06 Apr. 2024. .

Solutions, Vite . "Law of Equity and Trusts" Afribary (2021). Accessed April 06, 2024. https://afribary.com/works/law-of-equity-and-trusts-isochukwu

Document Details

Related works, analysis of the various schools of thought in relation to the meaning of law, critical analysis of corroboration under the nigerian law of evidence, a holistic appraisal of the concept of trust under the nigerian jurisprudence, applicability of natural law principles to the law of negligence in nigeria, roles of legislature in impeachment procedings under the 1999 constitution, provocation as a defence to criminal liabilty, an appraisal of international crimes and the operations of the international criminal court, the nigerian copyright commission and administration of copyright in nigeria (an appraisal), justification for and the abolition of capital punishment under human rights law, a critical appraisal of election laws in nigeria.

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• University Law
• PQ and Answers

BANKING 1.8 NEGOTIABLE INSTRUMENTS

Negotiable instruments..

Are simply documents capable of discharging debts.

Historically trade was by barter it was later replaced with money. As foreign territories interacted, trade and commerce began to boom. Negotiable instruments were issued for commercial expediency and convenience. Inter-state transportation of gold and silver coins was unattractive therefore, negotiable instruments were utilised especially where the merchant had a debtor in the target country. He could just order his debtor to pay the merchant who resides in the same foreign country.

A Negotiable Instrument:

• Is a written order/promise to pay money.
• Is negotiable: meaning that it is an assignable [1] chose in action [2] . Ordinarily, a chose in action could not be assigned (this was the common law position) however, equity allows assignment of a chose in action provided that prior notice has been given to the debtor. Unlike an assignment, Negotiable instruments do not require a deed of assignment to be executed.
• Is freely transferrable by mere delivery to a bona fide [3] holder for value free from equities [4] .
• Passes full legal title to the transferee who can sue in his own name.
• Value [5] is generally presumed to have been given for the negotiable instrument. By Section 27 of the Bill of Exchange Act, an antecedent debt or liability is valuable consideration [6] .

The following are NOT negotiable instruments:

• Bill of Lading: is a document showing that particular goods have been loaded on the ship. Although it is freely transferrable without need for notice and, transferee can sue in his own name, it is taken subject to equities [7] .
• Share Certificate: a document certifying that the shareholder named therein is the registered holder of the shares. Not freely transferrable . Unlike a share warrant [8] which is a negotiable instrument as it is transferrable by mere delivery. This distinction was noted in Webb Hale V Alexander Water .
• IOU: is a mere written acknowledgment of a debt. Mr A agrees in writing that he owes Mr B. It is not a negotiable instrument.

The Bill of Exchange Act 1917 codifies the following as negotiable instruments:

• Bill of Exchange.
• Promissory notes.

This notwithstanding, the court in Webb hale and co V Alexander Water ltd noted that the existence and evolution of other negotiable instruments has not been inhibited. Other negotiable instruments include: Share Warrants, Treasury Bills, traveller cheques, bearer bonds and debentures [9] , and so on. We take them one by one.

BILL OF EXCHANGE.

Section 3(1) of the Bill of Exchange Act defines it as:

An unconditional order in writing addressed by one person to another, signed by the person giving it, requiring the person to whom it is addressed to pay on demand or at a determinable future time, a sum certain in money or to the order of a specified person or a bearer. Anything else is not a bill of exchange.

By Section 4, an inland bill is drawn and payable within the country or upon a person resident therein.

By Section 3 (1) (2) and (3), for a document/bill to qualify as a bill of exchange:

• The bill must be an order : a mere request, plea or petition may not suffice. In Little V Slackford , a bill couching the request with the phrase, “ as you will much oblige your humble servant ” was held not to be a bill of exchange. But in Ruff V Webb “ will much oblige ” was accepted as a request.
• The instrument must be in writing : it does not have to be exclusively in English. For example; In Arab Bank Ltd V Ross , the court accepted a combination of Arabic and English writing.
• The instrument must be signed by the drawer: or his authorised agent. An initial, stamp or signature may suffice- Bennette V Brumfit . In Goodman V Eban , a rubber stamp was accepted [10] .
• The order must be unconditional : not subject to the performance of an act or occurrence of an event or availability of money in a fund- Section 3(2 and 3). Certainty is the watchword.
• The order must be addressed by the drawer [11] to an identified drawee [12] . In Mason V Lack , bill was invalidated as “pay to my order…” did not sufficiently indicate the drawee.
• The payee [13] must be named or indicated with reasonable certainty : where the bill is not payable to the bearer. In NSIC ltd V National Provincial Bank it was held that an instrument made payable to “ cash” or “ order” could not be considered a specified person, “ wages ” has also been refused. Where the bill is payable to a non-existing person, the bill would be treated as payable to the bearer- Section 7 BOEXAct.
• The order must be for a sum certain in money : whether payable with interest, by instalment or exchange – Section 9. In Smith V Nightingal , a promise to pay E45 and all other sums which may be due to him was not certain. What happens where (for example) the words say one hundred thousand and the figures say N1,000,000? Section 9(2) provides that the words prevail over figures in the event of inconsistency with figures.
• The bill must be payable on demand or at a fixed determinable future time : by Section 10, a bill is payable on demand where it expresses to be payable on demand or where no time of payment is prescribed. By Section 11, a bill is payable at a determinable future time where it is expressed to be payable at a fixed period after date or sight or after the occurrence of a specified and inevitable In Williamson V Rider , a note payable “on or before” a given date was invalidated. A bill is not invalidated by the mere fact that it is not dated [14] or that it does not specify place where it is drawn or payable. Section 3(4).

PARTIES TO A BILL.

The drawer : the person who draws an instrument and gives the order to pay. Once the bill has been drawn and signed, he is implied to have undertaken to compensate the payee if the bill is dishonoured.

The Drawee : the person legally obliged to honour the order to pay.

The payee : the person in whose favour the bill is drawn. The person who receives payment. It has been noted earlier that the payee must be identified with certainty where the bill is not payable to the bearer. If the payee is fictitious, the bill is treated as payable to the bearer- Section 7(3).

E.g. if by writing, Mr Chinueke properly instructs Chime (who owes him #500,000) to give Tayo #200,000. Chinueke is the drawer, Chime is the Drawee and Tayo is the Payee.

The person who approves a bill is the endorser while the endorsee is the person to whom it is endorsed. Endorsement of bills : Endorsement entails confirming the authority of the issuer. By endorsing it, the endorser is assuring that on due presentation, it shall be paid. Where it is not paid, the payee should be compensated. By endorsing, the endorser is also precluded from denying the genuineness or regularity of the drawer’s signature… he is also precluded from denying or questioning his endorsement- Section 55. Endorsement can be conditional, restrictive or prohibitive. Where an endorsement prohibits transfer, it is valid but not negotiable.

Holder : Section 2 defines a holder as the payee or endorsee in possession of the bill note or the bearer thereof. Meaning that to be a holder, the payee or endorsee must also be in possession of the bill. Where it is a bearer bill, any person in possession of the bearer bill is the holder. A holder for value is one who gives valuable consideration for a bill or has a lien thereon… one whose signature appears on the bill. By Section 29, a holder in due course is one: who takes a bill, complete and regular on the face of it provided:

• He took the bill before it was overdue. (3 days grace is provided after fixed date).
• He took the bill in good faith and for value without notice of the defect in title- Section 29(2).

Section 38 provides that a holder can sue in his own name.

Consideration for a bill.

By Section 30 and 27, consideration is presumed to exist where;

• Value has at anytime been given for the bill.
• The holder has a lien over the bill.
• There is an antecedent debt or liability.
• Where the party in question has his signature on the bill.

Where void/illegal consideration is furnished, no right of action lies except it is transferred to a third party holder for value without notice- Section 30(2).

The bearer : Section 2 of the act: is the holder of a bill payable to the bearer or a holder of a bill which last endorsement is in blank. Such bills can be negotiated by mere delivery. The bearer is not liable under the bill because his signature does not appear on the bill. Except he has transferred the bill for valuable consideration or the bill is found to be a forgery.

Negotiability of bills : The ability to transfer free of equities.  By Section 31 and Section 32, a bill is negotiated when it is transferred from one person to another. A bill payable to the bearer is negotiated by mere delivery. Where payable to order, in addition to delivery of the bill, there must be a written and signed endorsement of the whole bill for it to be negotiated.

Inchoate instruments: are incomplete instruments. Lacking any of the following; date of payment, specific value, or place where it is drawn or payable… provided that it does not lack the signature of the drawer. By Section 3(4) this does not invalidate the instrument. The person in possession of the bill can honestly and reasonably fill up such omissions – Section 20. Where a wrong value is inserted fraudulently, the drawer is discharged of liability except the bill comes into the hands of a holder in due course who has no notice of unauthorised filling. Inchoate bills are commonly found in blank cheques.

Acceptance : by Section 17, is a written assent on the bill signed by the drawee, agreeing to pay the specified money. Acceptance may be general , conditional [15] , partial [16] or local [17] . Acceptance compels the drawee to pay without challenging the existence, capacity or authority of the drawer or the genuineness of his signature- Section 54.

Dishonour occurs where the bill is not accepted on presentation. The holder can then sue the drawer or endorser.

DISCHARGE OF A BILL.

A bill may be discharged in the following circumstances:

• Payment in due course/ on presentation: by the drawee in good faith and without notice of any defect in the bill. Where payment is by drawer, the bill is not discharged.
• Where the bill is negotiated to the acceptor. I.e. where the acceptor becomes the holder of the bill in his own right rather than on trust.
• Where the holder waives the bill in writing.
• Where there is material alteration of the bill without the consent of the parties liable to it. Although the bill would still be valid against any of the parties that assented the alteration.
• Where the bill is cancelled.

By Section 73 of the BOEXA, a cheque is a bill of exchange drawn on a banker and payable on demand.

Unlike a bill of exchange, a cheque must be payable on demand, and drawn on the banker. Since the cheque is payable on demand, it does not need acceptance. The drawer of a cheque is meant to exercise reasonable care in drawing it unlike in a bill. The bank, unlike the drawee of an ordinary bill is protected against forged or unauthorised endorsement.

A cheque is an unconditional order in writing, signed by the drawer requiring a bank to pay a certain sum in money to the person to whom it is drawn or the order…

Flowing from the implications of the banker-customer relationship, a bank is to honour cheques drawn on it and the customer is to execute his order with due care- Joachinson V Swiss Bank Corporation . A wrongful dishonour of cheque can give rise to an action for breach. Damages presumed where the customer is a trader in other cases; nominal damages.

Types of cheques.

• Open cheque : payable over the counter of the drawee bank after ascertaining the identity of the payee.
• Crossed cheque : two transverse lines run across the face of the cheque. Crossed cheques are payable only into the account of the payee. A crossed cheque is advantageous in the sense that it forestall fraud as it is paid into account of intended payee. Also, fraudulent proceeds can be traced to the recipient’s account (This facilitates the Know Your Customer directive of the CBN). Also since it takes a longer time to clear, the bank has ample time to detect fraud and stop payment. The disadvantage of a crossed cheque is that it takes a longer time to clear and the payee is required to have an account.

Types of Crossing:

• General crossing : by Section 78(1) in addition to the two transverse lines, the words; “and company” may be included.
• Special crossing : by Section 78(2) an addition of the name of the banker with or without the words “not negotiable”. It is a cheque payable only to the banker specified in the crossing.
• Not negotiable crossing : Section 83, meaning the holder gets it subject to equities- Great Western Railway V London and County Banking Co . Protects the true owner from any subsequent transfer occasioned by loss or theft. Meaning he can recover the money even from a holder for value without notice.
• Account payee : that the money must be paid only into the account of the named payee (identified in the cheque). Payment into another account could make the bank liable in negligence and conversion- Abimbola V Bank of America as “account payee” puts the banker on inquiry and caution.

Duties of the paying bank same as the banker-customer relationship duties noted above.

Forged Signatures.

Forgery entails making a false document or writing with the intent that it may be acted upon as genuine…Forgery is a criminal offence punishable under Section 465 of the Criminal Code.  The court noted in ACB V Victor Ndoma that a cheque is forged where there is an unauthorised alteration of the amount, date, a fabrication of the signature(s) and other features of the cheque. Section 24 BOEXACT provides that such forged instruments are inoperative except the customer (drawer) is precluded from alleging forgery. For example in the case of Greenwood V Martins Bank , the customer became aware of the forgeries by his wife but kept quiet for 8 months. The court held that his silence gave rise to estoppel. At common-law, a banker who pays on a forged cheque can be liable to the true owner for conversion. However, Section 60 and 77 of the Bill of Exchange Act protects an innocent banker who pays on demand in good faith and in the ordinary course of business .

THE COLLECTING BANKER.

A collecting bank is a bank which receives a cheque on behalf of its customer for clearing and collection before placing the value on customer’s account. In Gordon V Capital and Counties Bank Ltd the court likened such function to a situation where a customer gives his clerk a cheque to cash on his behalf.

For example, a Mr A Draws a First Bank Cheque payable to Mr B who has a UBA account. Mr B presents the cheque to UBA (his bank). UBA takes the cheque to First Bank and receives the money on behalf of Mr B. This  money is then credited (by UBA) into Mr B’s UBA account. Section 77(2) protects a collecting banker from liability (in the event of fraud or defective title) provided the collecting banker acted in good faith and without negligence. “ Good faith ” by Section 92 is where the act was done honestly. The whole transaction must have been done in good faith- Gordon V Capital and Counties Bank Ltd.

The duty of care required in handling cheques : owed to the customer. In Taxation Commissioners V English Scottish and Australian Bank , the court held that we must equate to the cashiers and clerks handling the cheque the intelligence of ordinary persons in their position. The bankers have to prove that they were not careless. The banker must ensure that it:

• Obtains reference: like driver’s licence, passport, I.D card and so on.
• Verifies endorsements .
• Acts wisely: for example, the bank should ensure that it pays money for a corporate establishment into the corporation’s account rather than into a private account. It is negligent to collect for a man’s private account, cheques made payable to him in his official capacity. In Midland Bank V Reckitt , notwithstanding that the attorney was authorised to draw without restriction, the court held a bank liable in negligence for collecting a cheque drawn by an attorney from his principal’s account.

PROMISSORY NOTES.

By Section 85 of the Act: A promissory note is:

• A written and unconditional [18] promise to pay.
• Signed by the person making the promise.
• To pay a sum certain in money.
• On Demand or at a fixed determinable future date.
• To a specified person or to the bearer.

Unlike a bill of exchange that has 3 parties, here there are only two parties. The Promisee and promissor. Also, unlike the Bill of exchange which must be an order, the promissory note is a promise.

An IOU is not a promissory note because it does not specify date of payment nor does it specify the person to be paid. It is a mere acknowledgement of indebtedness in writing.

A promissory note is inchoate until delivered to the payee or bearer- Section 86.

JOINT AND SEVERAL NOTES.

By Section 87 of the act a promissory note can be made by two or more persons jointly and severally. It is made jointly where the note begins with; “we promise to pay” while it is made severally where it begins with “I promise to pay”. It is joint and several where it begins with: “the makers jointly and severally promise” here either of them can be sued and a contribution can be recovered from the other party.

There should be some consideration passing from the promissee to the promissor for him to succeed in a suit- Gbebamose V Mbadire .

REFERENCES.

Goldface-Irokalibe, I. J. Law of Banking in Nigeria. (Malthouse Press Limited, Lagos). 2007.

Layi Afolabi – Law and Practice of Banking.

Commercial Law in Nigeria. Akanki.

National Open University: Law of Banking and Insurance.

[1] Assignment involves a transfer of right from one person to another.

[2] A chose in action is a right that is enforceable by legal action rather than by taking possession. E.g. recovery of debts, shares, and so on.

[3] a person who takes the instrument for value in good faith without notice of defect in title.

[4] Notwithstanding that the transferor has a defective title.

[5] Anything of value like; money, goods or services.

[6] I.e. where the transferor owes the transferee some money.

[7] Where the transferor has a defective title, the right of the holder is vitiated.

[8] Which states that the bearer is entitled to the shares stated therein

[9] Issued by a company acknowledging its indebtedness to the holder or bearer

[10] Although Lord Denning dissented in this case stating that a rubber stamp lacks the uniqueness of a hand written signature

[11] The person making the bill…. The person giving the order.

[12] The debtor… the person that is to pay the bill.

[13] The person in whose favour the bill is drawn… The person to receive the money.

[14] Like “ this bill is drawn on the 25 th December, 2015”.

[15] Subject to the performance of act or qualified as to time.

[16] Accept to pay only a part of the amount.

[17] To pay at a particular place and nowhere else.

[18] Not subject to conditions or contingencies which may or may not occur.

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A chose in action is essentially the right to sue. It is an intangible personal property right recognized and protected by law, has no existence apart from the recognition given to it by law, and confers no present possession of a tangible object.[i]  In Hospital Serv. Corp. v. Pennsylvania Ins. Co. , 101 R.I. 708, 709 (R.I. 1967), the court held that common law forbids assignment of causes of action for personal injuries.

However, in Summers v. Freishtat , 274 Md. 404, 409 (Md. 1975), the court held that “a chose in action in tort is generally assignable, in the absence of a statutory prohibition, if it is a right which would survive the assignor and could be enforced by his personal representative.”  Therefore, assignment of choses in action is possible if not expressly prohibited by statutory or contractual provisions.

An assignment of a chose in action will not confer upon the assignee a right of action in his/her own name against the original debtor.  But if either the debtor expressly promises to pay the assignee or the assignment is made with the debtor’s assent, then the assignee has the right to action in his own name.[ii]  Further in Gillespie v. De Witt, 53 N.C. App. 252, 262 (N.C. Ct. App. 1981), the court held that “an assignment of a chose in action operates as a valid transfer of the title to the chose in action and the assignee becomes the real party in interest who may maintain the action in his or her own name.”

[i] http://en.wikipedia.org/wiki/Chose

[ii] http://chestofbooks.com/business/law/Law-Of-Contracts-Treatise/Assignment-Of-A-Chose-In-Action.html

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Chose in Action

Practical law canada glossary 0-621-0054  (approx. 2 pages).

• Canada (Common Law)

ASSIGNMENT OF CHOSES IN ACTION. The term "assignment" refers to the act of transferring to another all or part of one's property, interest, or rights. The term denotes not only the act of transfer, but also the instrument by which it is effected. 9 In Julius Berger (Nig) Plc & Anor v.

The process of transfer of such a right is known as "assignment" and the types of property which are susceptible to this type of transfer are known as "choses in action.". This article sets out to trace the evolution, incidence, and the conditions precedent for a valid assignment of choses in action under Nigerian law.

A chose in action may be: 2.1 Legal Chose in Action: Recoverable by action at common-law. for example debt, copyright, shares, and so on. 2.2 Equitable Chose in Action: only enforced by proceeding in equity like fund, or legacy under a will. At common-law, only a legal chose could be assigned provided the consent of the debtor was obtained.

In other words you can either claim your chose in action directly or opt for assignment to benefit from. Dr. AbdelGadir Warsama. LEGAL COUNSEL. Email: [email protected] . Previous Post. Next Post. As a rule, choses in action are your rights that you must claim. They are not in your actual possession to benefit from them, rather you may lose.

For such assignment to be lawful and effective, there are basic conditions that must be fulfilled, according to the Supreme Court of Nigeria. 1. The Supreme Court of Nigeria in the case of FERDINAND GEORGE v. UNITED BANK FOR AFRICA LIMITED (1972) LPELR-1321 (SC), where the court held that; "Obviously, where the burden of a debt is being ...

Abstract. This chapter deals with the general law of assignment of choses in action. Beginning with the historically based difference between equitable and statutory assignment, it then explains what 'chose in action' and 'assignment' are before discussing the requirement that there be an existing and assignable chose in action or right as well as the requirement that a person who ...

There is a dearth of Nigerian judicial authorities on assignment of choses in action. This exiguity was observed in Julius Berger Nigeria Plc v T.R.C.B. Ltd [2010] 9 NWLR (Pt 1198) 80 at 106C-D. This discourse assesses the significance of notice to debtors in debt assignments. It is certainly not an exhaustive thesis on this issue.

This chapter studies the requirements that are necessary for an effective assignment of choses in action. In order to effect the assignment or a chose in action: the assignor must have manifested an intention to transfer the chose; the thing being assigned must be a chose in action, in present existence, certain or capable of being ascertained; the identity of the assignee must be clear; and ...

NIGERIA. UK (LIMITED) WACA Subject matter Equity Choses in action ; notification_add Follow for updates . Conditions for the assignment of choses in action ... Whether the beneficiary of an assignment of a chose in action needs to furnish any consideration to the debtor

assignment of choses in action. distinction between novation and assignment. the doctrine of conversion. the doctrine of satisfaction. the doctrine of performance . the doctrine of election. the remedy of injunction. specific performance. the remedy of rescission. rectification. defences available to equitable remedies. equity part ii/law of ...

Abstract. This chapter deals with the general law of assignment of choses in action. Beginning with the historically based difference between equitable and statutory assignment, it then explains ...

LAW OF EQUITY AND TRUSTS PART I AND II TABLE OF CONTENTS LAW OF EQUITY PART 1 DEFINITION OF EQUITY. NATURE, ORIGIN AND RECEPTION OF EQUITY. THE MAXIMS AND PRINCIPLES OF EQUITY NATURE OF EQUITABLE INTEREST AND THE DOCTRINE OF NOTICE..9 EQUITABLE INTEREST AND LEGAL ESTATES THE DOCTRINE OF NOTICE. PRIORITY. PARTICULAR EQUITABLE INTERESTS. ASSIGNMENT OF CHOSES IN ACTION. DISTINCTION BETWEEN ...

ASSIGNMENT OF CHOSES IN ACTION. DISTINCTION BETWEEN NOVATION AND ASSIGNMENT. THE DOCTRINE OF CONVERSION. THE DOCTRINE OF SATISFACTION. THE DOCTRINE OF PERFORMANCE. ... Equity has been received into Nigeria (first) by Ordinance no. 3 of 1863, Supreme Court Ordinance 1914. The position is that the rules of common-law, doctrines of equity and ...

At common law the general rule was that unless the debtor agreed to it, a debt or other chose in action could not be assigned This is because chose...

Commercial Law in Nigeria. Akanki. National Open University: Law of Banking and Insurance. Assignment involves a transfer of right from one person to another. A chose in action is a right that is enforceable by legal action rather than by taking possession. E.g. recovery of debts, shares, and so on.

1. Introduction PART I: CHOSES IN ACTION AND THEIR NATURE 2. Nature and characteristics of choses in action 3. Classification and creation of choses in action 4. Contracts and third parties PART II: THE TRANSFER OF CHOSES IN ACTION 5. Transfer of choses in action: Historical overview 6. Conceptual underpinnings 7. Assignment of choses in action 8. Transfers of choses in action on trust 9 ...

ASSIGNMENT OF CHOSES IN ACTION 623. covenantor and debtor"; between the assignment of a contract as such, and the transfer of a debt which has arisen from the con- tract.4 It requires a statute to impair that freedom of transfer, which is part of the concept that a chose in action is really "prop-.

516 FORDHAM INTERNATIONAL LAW JOURNAL [Vol. 45:3 property in the form of a chose in action.6 And precisely because the law considers that chose in action to be property, property law provides that it can be transferred by assignment to another. 7 Once assigned, the assignee may typically proceed against the defendant

1. The other main body of doctrine enabling the transfer of rights created by contract is the law of negotiable instruments, which are uncontroversially transferable. 2. The most comprehensive scholarly treatment of the topic is Tolhurst, G., The Assignment of Contractual Rights, 2nd ed. (Oxford 2016) Google Scholar.

Choses in action were not originally assignable at Common Law to enable the Assignee sue in his own name, because debts or choses in action were regarded as personal - LAMPET'S CASE (1613) 10 CO-REP 46B, 48. An attempted assignment was seen as an intrusion by a third party, into a dispute between two parties.

Freishtat, 274 Md. 404, 409 (Md. 1975), the court held that "a chose in action in tort is generally assignable, in the absence of a statutory prohibition, if it is a right which would survive the assignor and could be enforced by his personal representative.". Therefore, assignment of choses in action is possible if not expressly prohibited ...

Chose in Action. Personal rights of property which can only be claimed or enforced by action and not by taking physical possession (as distinct from choses in possession, things capable of physical possession). Divided into legal and equitable choses in action, depending on whether they can be recovered or enforced by action at law (such as ...

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