Consideration AO3
Consideration is defined in Curie V Lisa- "a benefit, interest or some detriment"
It is a “Bargain not a gift”
Consideration needs to be adequate, not sufficient
"adequate but not sufficient" - Thomas V Thomas - £1 a year for rent
+ supports idea for the freedom of contract, no matter how bad
- If it involves fraud, unfair pressure its difficult to prove
No consistency with what is sufficient for emotional promises
White V Bluett - note being written off for son not to complain was not consideration
but Ward V Bytham- promise to keep daughter happy was sufficent consideration
+ emotional promises lack certainty, objectively (because its not in money terms), makes it fair to be not sufficient
- difficult to prove what is or isn’t consistent
Past consideration is no consideration
Re McArdle- promise given for work done on house after work was complete, not sufficient
exception- implied promise Lampleigh V Braitwath- getting the king's pardon was sufficient
+ act done in the past is like a gift, this rule prevents opening of floodgates (promise of reward after volunteer work)
- Lampleigh exception difficult to establish, risk of inconsistent outcomes
Performing existing duty wont be sufficient consideration for a new contract
Stilk V Myrick- 2 crew deserted, promise of higher pay was not sufficient consideration as work was meant to be performed under existing duty
Exceptions-
Extra benefit done- Ponosoby- extra risk because of danger, half the crew deserted
practical benefit- Roeing, prevented penalties being imposed on builders if the subcontractor did work quicker (practical benefit)
The promise of payment comes from 3rd party- Shadwell V Shadwell (uncle to pay instalments until nephew married fiance)
+ Fair as one party giving nothing new in return for extra payment would be wrong
- difficult to prove what is extra something done, Ponosoby and Stilk contrast
→ courts moving away from this rule, accepting that new changes in contracts are being more popular, should be enforced- doing it to prevent penalties in Roffey V Williams
Conclusion
*Consideration has not been considered by the law body since 1947- too complicated
*some argue consideration should be abandoned, as intention to create legal relations sums it up anyways