Hirachand Punamchand v Temple [1911] 2 KB 330 is often cited as one of the exceptions to the accord and satisfaction rule laid out in Foakes v Beer.

In Hirachand Punamchand v Temple, part payment of a debt is held to be valid because it is supplied by a third party and not the debtor (originally established in Cook v Lister (1863) 13 CBNS 543).

The money lenders cashed the cheque but then proceeded to sue the debtor (Lieutenant Temple) for the outstanding balance.

Fletcher Moulton LJ said in the ruling: But in the present case we are dealing with the question of the effect of money paid by a third person [and not by the debtor].

Here the money was paid by a third person, and I have no doubt that, upon the acceptance of that money by the plaintiffs with full knowledge of the terms on which it was offered, the debt was absolutely extinguished.The net effect of the father's intervention was to essentially extinguish the original credit note; in the words of Vaughan Williams LJ: the document had ceased to be a negotiable instrument quite as much as if there had been on the acceptance of the draft by the plaintiffs an erasure of the writing of the signature of the noteHe had previously said (regarding the draft): They not only kept it, but they cashed it, and if they changed their minds afterwards, it was too late.Thus arriving at an essentially similar position to that of Willes J in Cook v Lister (1863) 13 CBNS 543 (in which he expressed the view that the "effect of such as agreement between a creditor and a third party with regard to the debt is to render it impossible for the creditor afterwards to sue the debtor for it") but by virtue of rather different reasoning.