The fact that a broker employed to effect a sale is a director in the corporation which he procures to buy the property, does not prevent him from recovering a commission, where the person who practically owns the capital stock of the corporation consented to the transaction, the question of fair dealing being submitted to the jury. Goldshear v. Barrow, 85 1ST. Y. S. 395, 42 Misc. 198. Mere consent by a person to the rendition by a real estate agent of unsolicited services which result in a sale of the property, does not, of itself, create a contract or entitle the broker to recover compensation under an implied promise of remuneration for such voluntary services. Viley v. Pettit, 96 Ky. 576, 16 Ky. L. R. 650, 29 S. W. 438; Weinhuse v. Cronin, 68 Conn. 250, 36 A. 45. Contra, Kinder v. Pope, 106 Mo. App. 536, 80 S. W. 315.

T and W entered into a contract with O to sell real estate for him within a certain time, on certain commissions; before the expiration of the time O requested the return of the agreement; W offered to purchase the land himself rather than lose the sale; the relation between the parties was that of principal and agent, and could not be changed without O's consent into that of vendor and purchaser. Tower v. O'Neil, 66 Pa. St. 332. See also Secs. 477, 478.

Where a seller, in order to. delude the purchaser as to the amount of commission to be paid on a sale of property, authorized the broker to deal with the purchaser for compensation. This was not such bad faith on the part of the broker as precluded him from recovering compensation from the seller. Siler v. Perkins, 140 S. W. 1060, 126 Tenn. 380, 47 L. R. A. (N. S.) 232.

Though the owner did not know when contracting with plaintiff to procure a purchaser that plaintiff was also acting for the other party, plaintiff might recover commissions if such relation had been terminated when defendant learned thereof. T. A. Hill & Son v. Patton & Schwartz, 160 S. W. 1155, - Tex. Civ. App. - .

The rule which precludes a real estate agent from representing both vendor and purchaser, though claiming to act as middleman, is intended to secure honest service, and to enable both vendor and purchaser to know whom he is serving. Clopton v. Meeves, 133 P. 907, 24 Idaho, 293.

In the case of an agreement for an exchange of land procured by a broker, facts may warrant recovery of commissions from one party but not from the other. Levy v. Dusen-berry, 163 P. 231, 32 Cal. App. 411.

"Where a realty broker brought together his principal, with land for sale, and another person for whom he was acting to effect an exchange, in which event he would have received a commission from both, without either having knowledge of the double agency, the law will not give effect to the agent's act by awarding him a commission against complaining principal with land for sale, simply because the other principal did not exchange lands, but sold them and bought lands of first principal. Buck v. Woodson, 209 S. W. 244, - Tex. Civ. App. - .

Where the bookkeeper for buyers of a plantation did not accept the proposition of the agent for the sellers to act as sub-agent, but refused his offer to share commission and elected to represent his employers in an offer to buy at lower than list price, negotiating direct with the sellers and acting for the buyers, without intimating either to the sellers' agent or the sellers that he was representing the latter, he is not entitled to recover from the sellers' agent half of the commission voluntarily paid such agent by the sellers. Henry v. Lamens-dorf, 83 S. 727, - Miss. Sup. - .

Agreement by a broker with an owner, giving the broker the right to sell on commission, and also giving him the right to purchase the property for himself, was not within the rule forbidding a broker buying from or selling to an employer, as the owner, by voluntarily signing the contract, must know that it provides for the broker's purchase for himself. Fitzgerald v. Boyle, 193 P. 1109, - Utah Sup. - .

"Where a contract gave a broker an option to purchase himself or to find a purchaser, he is, on purchasing the property himself, entitled to deduct the agreed commission, just as if he had negotiated a sale to a third person. Id.

Where a broker sold the owner's land to his wife, and the contract and deed were placed with a depositary to be delivered to the purchaser in compliance with the terms of the contract, the relationship between the purchaser and the broker held, to furnish no ground for refusing to complete the transaction, the owner being fully informed of such relationship before the contract was executed. Neal v. Owings, 194 P. 324, - Kan. Sup. - .