Stilk v Myrick [1809]

Two seamen deserted on course of voyage.
Captain promised rest of crew that if they stayed,
wages of deserters would be divided amongst them.
Held that there was no consideration for this promise.
‘Before [the crew] sailed from London they had undertaken
to do all they could under all emergencies of the voyage … The desertion of a
part of the crew is to be considered an emergency’
[Would have been different had promise been made eg to
diffuse dispute]