Halsall v Brizell [1957] Ch 169 is an English land law case, concerning the enforceability of a positive covenant, that is required positive obligations, in this case the obligation to pay money for upkeep and repair.

Brizell, a successor of an original purchaser (buyer from the developer), wished to continue to benefit from all of these but claimed he should not need to pay, as payment was a positive covenant.

Until this case, conflicting decisions pointed to a narrow category of application of positive covenants (chiefly limited to for example the obligation to erect and maintain railings or fences) could bind successors (beyond the first covenantor, that is purchaser or donee) owning freehold land.

Mr Justice Upjohn held that Brizell could not claim the benefit of the facilities without having to pay for them.

In the present case the owners of Walford House could not in theory or in practice be deprived of the benefit of the mutual rights of support if they failed to repair the roof.