Until modern statutory reforms in contract law, a seal was widely recognised by courts in common law jurisdictions as removing the need for consideration (value) in a contract. This reflects classical contract theory, in which consideration was viewed as a formal aspect of a contract, so that a seal could be considered an alternative form. A seal was not "per se" a type of consideration, but rather raised a presumption of consideration (courts have varied in their opinions of whether this presumption was rebuttable). See, e.g., Marine Contractors Co. Inc. v. Hurley, 365 Mass. 280, 285-86 (1974).