In Virginia the rule which was laid down originally was unfavorable to the right of the beneficiary to enforce the contract.1 This was subsequently modified by a statute which provided that a beneficiary might sue if the contract was intended for his sole benefit. This statute is said to have been enacted in order to prevent the promisor from being exposed to a double liability,2 but it has been explained as though it authorized the beneficiary to sue on a contract which was made primarily for his benefit.3 Under such a statute, a creditor can not maintain an action against a grantee who has assumed and agreed to pay debts due from the grantor to the creditor, since such covenant is for the benefit of the grantor as well as for the benefit of the creditor.4 On the other hand, the beneficiary of an insurance policy may maintain an action against an insurance company, which has agreed to pay such certificate, together with other obligations, in consideration of the transfer to the promisor of the assets of the insurance company which originally issued such policy.5