Combe v Combe [1951]

Shows that courts reluctant to extend promissory
estoppel doctrine in such way as to abolish doctrine of consideration by back
door.
Husband promised wife £100 a year on divorce.
She therefore did not apply to courts for maintenance.
Court of Appeal held her forbearance from applying for
maintenance was no consideration for promise of £100, as wife’s forbearance had
not been requested and was not in return for promise made to her.
Nor could wife rely on promissory estoppel:
Denning LJ:
‘Seeing that [estoppel] can never stand alone as
giving a cause of action in itself, it can never do away with the necessity of
consideration’