<Li> Rama Corporation Ltd v Proved Tin and General Investments Ltd (1952) 2 QB 147, Slade J, "Ostensible or apparent authority...is merely a form of estoppel, indeed, it has been termed agency by estoppel and you cannot call in aid an estoppel unless you have three ingredients: (i) a representation, (ii) reliance on the representation, and (iii) an alteration of your position resulting from such reliance ." </Li> <P> In the case of Watteau v Fenwick, Lord Coleridge CJ on the Queen's Bench concurred with an opinion by Wills J that a third party could hold personally liable a principal who he did not know about when he sold cigars to an agent that was acting outside of its authority . Wills J held that "the principal is liable for all the acts of the agent which are within the authority usually confided to an agent of that character, notwithstanding limitations, as between the principal and the agent, put upon that authority ." This decision is heavily criticised and doubted, though not entirely overruled in the UK . It is sometimes referred to as "usual authority" (though not in the sense used by Lord Denning MR in Hely - Hutchinson, where it is synonymous with "implied actual authority"). It has been explained as a form of apparent authority, or "inherent agency power". </P> <P> Authority by virtue of a position held to deter fraud and other harms that may befall individuals dealing with agents, there is a concept of Inherent Agency power, which is power derived solely by virtue of the agency relation . For example, partners have apparent authority to bind the other partners in the firm, their liability being joint and several (see below), and in a corporation, all executives and senior employees with decision - making authority by virtue of their declared position have apparent authority to bind the corporation . </P> <P> Even if the agent does act without authority, the principal may ratify the transaction and accept liability on the transactions as negotiated . This may be express or implied from the principal's behavior, e.g. if the agent has purported to act in a number of situations and the principal has knowingly acquiesced, the failure to notify all concerned of the agent's lack of authority is an implied ratification to those transactions and an implied grant of authority for future transactions of a similar nature . </P>

Which of the following type of agent has the most limitations on authority