1. INTRODUCTION The recent Supreme Court decision in MWB v Rock Advertising[1] has been the subject of much criticism[2] for its failure to address the issue as to what constituted valid consideration. Had such an evaluation taken place, it would have gone a considerable way towards clarifying the current law on consideration and resolving the tension between Foakes v Beer and the concept of ‘practical benefit’ in Williams v Roffey. However, Lord Sumption, delivering the judg