to most promises for which there is nothing given or received in exchange." Clearly, if the courts take the Williams v Roffey principle to its logical conclusion it could lead to the de facto abolition of the doctrine of consideration. Mckendrick concludes his remarks on p100 of his book by observing: , "There is no room for the doctrine of consideration in the Principles of European Contract Law article 2.101 which states|: (1) A contract is concluded if: (a) the parties intend to be legally bound; and (b) they reach a sufficient agreement without any further requirement (2) A contract need not be concluded or evidenced in writing nor is it subject to any other requirement as to form. The contract may be proved by any means, including witnesses. 6. A subsidiary, but not unimportant point, is the issue of whether it would be appropriate to raise estoppel. For reasons which will be made clear in the second half of this opinion analysis, estoppel cannot create a cause of action but can only act as a defence to a cause of action and in the present case, there is no need to plead estoppel because it is likely the court would accept the Williams v Roffey principle here and find for the claimant who would be unlikely to raise estoppel here when it is likely they would succeed under Williams v Roffey 7. It is perhaps, in closing, worth noting an extract from Professor Atiyah from thirty years ago: ?The