Explanation:

Correct option 3: Goodhart

The statement: “The strict view of English law is that if a tram company has no power to run buses, then any bus drivers engaged are not in law the servants of the company, and therefore the company is not liable for their torts.”

was not made by Lord Denning, but by Professor A.L. Goodhart, a renowned legal scholar and former editor of the Law Quarterly Review.

Context:
This observation was made by Goodhart in the context of discussing the doctrine of ultra vires and its implications on vicarious liability in English company law.

He highlighted how the strict application of ultra vires can lead to seemingly illogical or unjust results—like a company not being liable for the actions of people it hired, simply because the activity itself was beyond the company’s legal powers.