estoppel may provide the debtor with relief. The Court of Appeal in June 2016 in MWB v Rock Advertising revisited the issue of whether the practical benefit doctrine could be applied to decreasing pacts or agreements to accept less. Arden LJ and Kitchin LJ both endorsed this approach indicating that part payment along with practical benefit could be enough to support a promise to accept less. The decision has been criticised as extending the practical benefit test beyond its limits. Existing duties to third parties Consideration for a promise can be the performance of a contractual duty owed to someone other than the promisor. In Shadwell v Shadwell, Cayley Shadwell was under a contractual duty with a third party to marry. His uncle, Charles Shadwell promised to pay him £150 per year after he was married. It was held that Cayley Shadwell marrying was good consideration, notwithstanding that he was obliged by a contract with a third party to marry in any event. A promise to perform a pre-existing contractual duty owed to a third party (as opposed to the performance of that duty) may also amount to consideration.NZ Shipping Co Ltd v A M Satterthwaite & Co Ltd. Estoppel Central London Property Trust Ltd v High Trees House Ltd.Hughes v Metropolitan Rly Co.D & C Builders v Rees.Ogilvy v Hope Davies.Combe v Combe.Re Selectmove Ltd.Collier v P&MJ Wright (Holdings) Ltd.Waltons Stores (Interstate Ltd) v Maher.Crabb v Arun District Council.Avon County Council v Howlett a person can be estopped from denying what he said in a representation. Deeds and formality Law of Property (Miscellaneous Provisions) Act 1989 (UK) section 1 AlternativesCarlill v Carbolic Smoke Ball Co AL Smith LJ, I understand that if there is no consideration for a promise, it may be a promise in honour, or a nudum pactum; but if anything else is meant, I do not understand it. I do not understand what a bargain or a promise or an agreement in honour is unless it is one on which an action cannot be brought because it is nudum pactum. In my judgment, this first point fails, and this was an offer intended to be acted upon, and, when acted upon and the conditions performed, constituted a promise to pay.Antons Trawling Co Ltd v Smith, Baragwanath J, "The importance of consideration is as a valuable signal that the parties intend to be bound by their agreement,