The sister married after the father's death, and the son refused to make good the promised sum (equivalent to £196,000 in 2023).

[6] This exception was for almost a century from 1884 considered not part of the common law,[7] and was directly refuted in Tweddle v Atkinson (1861).

[8] The legal and equitable narrow exemptions of Dutton v Poole (to the same effect) were in 1967 in a very limited way re-endorsed.

The Judicial Committee of the House of Lords case Beswick v Beswick confirmed their application to Executor-claimants seeking equity's assistance to enforce promises to pay them indirectly contained in contracts between third parties and the deceased.

The leading judges expressed a great deal of regret in the statutory law not having loosened the doctrine still further (which took place 32 years later in 1999).