And at page 84: …there must be, as Lennox J. said in Loranger v. Haines, “reciprocal undertakings”. So if one party is neither giving anything, nor is promising to do or give anything, there is no consideration for the other party’s act or promise. What is meant here by the expression “value” must not be taken in a literal, entirely materialistic sense. In most instances, of course, it will be money or money’s worth that is involved. But it is not so exclusive. Consideration means something which is of some value in the eyes of the law. It must be real. This could include some act, or promise of an act, which is incapable of being given a monetary value, though it has value, some benefit, in the sense of advantage for the party who is the present or future recipient or beneficiary of the act.
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