The importance of promissory estoppel in contract law is that it has enabled legal obligations, which fall into the category of contract law but fail to show any consideration, to be argued for. Promissory estoppel provides a way in which promises can be legally binding even if no consideration has been given. Promissory estoppel relates to a form of future conduct. The doctrine of promissory estoppel may not make the total contract fully enforceable. The specific facts in the case must actually establish the elements of promissory estoppel before the contract becomes enforceable in law. The promises within a contract will be enforced under the promissory estoppel doctrine, when enforcing the contract promises avoids injustice. Lord Justice Denning is a leading figure in the field of promissory estoppel in the case of Central London Property Trust Ltd v High Trees House Ltd was concerned with the modification of the rent payable on a block of flats during the Second World War. The importance of the case, however, lies in an obiter statement of principle which Denning LJ set out, “a promise intended to be binding, intended to be acted on, and in fact acted on, is binding so far as its terms properly apply”. Applying this principle, Denning held that a promise to accept a lower rent during the war years was binding on the landlord, regardless of the fact that the tenant had supplied no consideration for it. There are limitations which must be satisfied to this doctrine which derived from both Lord Cairns in the case Hughes v Metropolitan Railway Co and Denning LJ in the High Trees case. They are: There must be a promise There must be a clear promise intended to alter the contracted obligation. The court assesses intention objectively rather than taking evidence on the party's state of mind. Woodhouse Israel Cocoa Ltd v Nigerian Produce Marketing Board held that a contract for the sale of some coffee beans was agreed to be payable in sterling. The sellers mistakenly sent an invoice stating price was payable in Nigerian pounds. At the time the value of sterling and the Nigerian pound was equal. The buyers accepted the delivery and invoice without objection. Subsequently, the value of sterling fell quite dramatically in relation to the Nigerian pound. The buyers then sought to revert to sterling as stated in the contract. The buyers conduct in accepting the