at arm’s length it is unnecessary for the achievement of justice’. On the idea of past consideration, Lord Scarman said this: On the point of duress, Lord Scarman held the following. This was commercial pressure and no more, since the company really just wanted to avoid adverse publicity. For a general doctrine of economic duress, it must be shown ‘the victim’s consent to the contract was not a voluntary act on his part… provided always that the basis of such recognition is that it must amount to a coercion of will, which vitiates consent.’ See also Iniquitous pressure in English law Universe Tankships Inc of Monrovia v International Transport Workers’ Federation [1982] 2 All ER 67 Atlas Express Ltd. v. Kafco [1989] QB 833 North Ocean Shipping Co. Ltd. v. Hyundai Construction Co., Ltd. [1979] QB 705 Notes References PS Atiyah, 'Economic Duress and the Overborne Will' (1982) 98 LQR 197 D Tiplady, 'Concepts of Duress' (1983) 99 LQR 188 PS Atiyah, 'Duress and the Overborne Will Again' (1983) 99 LQR 353 English enforceability case law English consideration case law English duress case law English unconscionability case law Judicial Committee of the Privy Council cases on appeal from Hong Kong 1980 in case law 1980 in Hong Kong 1980 in British law