Foakes v Beer [1884]

B obtained judgment for repayment of sum owed to her
by F.
B agreed that if F paid full sum in instalments she
would not take ‘any proceedings whatever’.
F paid exactly as required, but B then claimed
interest.
House of Lords held that there was no consideration
for the promise to take no proceedings.
It was simply a gratuitous contract.
F therefore had to pay the interest.