The Court of Appeal, in "Re Selectmove Ltd", stated that the "practical benefit doctrine", arising from "Williams v Roffey", cannot be used as an additional exception to the rule. In that case, it was held that the doctrine only applies where the original promise was a promise to pay extra and not to pay less. The Court of Appeal in "Re Selectmove" were unable to distinguish "Foakes v Beer" (a House of Lords decision), in order to apply "Williams v Roffey" (a Court of Appeal decision). It therefore remains to be seen whether the House of Lords would decide this point differently. In any event, the equitable principle of promissory estoppel may provide the debtor with relief.