contractual enforcement. In general Atiyah's work was concerned with finding the concepts of justice lying behind the juridical techniques of private common law, concept which he regarded as the real motivators for the way in which cases were decided. Treitel on the other hand believed that the law of contract could be described accurately in terms of a coherent set of rules, and his textbook is the result of that approach. *** 5.2 Valid consideration Three conditions must be satisfied: Consideration must be sufficient but need not be adequate. Consideration must not be past. Consideration must move from the promisee but need not move to the promisor. 5.2.1 Consideration must be sufficient but need not be adequate The consideration must have some value The court is not concerned with the adequacy of the consideration. In the absence of duress or undue influence the court will uphold a contract even where it appears that the consideration, objectively viewed, is not adequate. Chappell & Co v Nestle [1960] AC 87 Nestle offered a popular record of the day in return for 1/6d and three wrappers from their chocolate bars. The House of Lords HELD that the wrappers were a good consideration despite the fact that the wrappers had little direct value and were in fact thrown away. Atiyah argues that this case illustrates the deficiency of the benefit/detriment analysis of consideration. What is ?value?? Treitel argues that the consideration must have some economic value even though the value is not capable of