The issue before the court was whether the police authority had provided fresh consideration for Glasbrook Bros' promise to pay.

The colliery owners repudiated liability on the grounds that there was no consideration for the promise to pay for the police protection and that such an agreement was against public policy.

It has long been accepted that where a party merely does something by which he is already legally bound this can never be sufficient to amount to consideration for an entirely fresh agreement.

It will be adequate consideration where what is given is more than could have been expected from performance of the existing duty, where in fact something extra is added to what the claimant is already bound to do.

Stilk v Myrick The Glamorgan Coal Company v. Glamorganshire Standing Joint Committee (1916, 2 K.B.D) Ward v Byham [1956] 1 WLR 496 Court of Appeal North Ocean Shipping Co Ltd v Hyundai Construction Co Ltd