A universal agent is of exceeding rare occurrence. Such an agent would be one with authority to perform all acts for the principal which his principal might perform in person and which he could legally delegate to another to perform.1 This in effect would be making the agent the master, and the principal a figurehead only. Most of the so-called, imagined, universal agencies would therefore properly be considered as extended general agencies and an indiscriminate use of the term universal is not encouraged in defining extreme authority in any direction.

1 See the following cited case for what was termed a universal agency. Barr- vs. Schroeder, 32 Cal., 609. Special Agent.

White vs. Tuckett, 15 East, 400; Anderson vs. Cooney, 21 Wend., N. Y., 279.