In the earlier case of , Mansfield had tried to challenge the doctrine of Consideration. In English law, "Consideration" is a vital part of the contract; without valid consideration, almost any contract is void. But, Mansfield argued in his judgment that it should only be treated as evidence of a contract, not as a vital element. Mansfield failed to make clear that he was referring only to consideration in commercial contracts, not general contracts, and as a result his judgment read that consideration was not required for "any" contract. His judgment has been much criticised by legal academics, and was effectively overruled by the House of Lords in "Rann v Hughes" 7 T. R. 350.