In re Selectmove Ltd [1993] EWCA Civ 8 is an English contract law case concerning the legal doctrine of consideration and partial payment of a debt.
Selectmove Ltd owed the Inland Revenue substantial sums in outstanding tax and national insurance.
The High Court held that even if that were found to be true, Mr Polland had not bound the Revenue, and there was no consideration for the varied agreement anyway.
Peter Gibson LJ (Stuart-Smith and Balcombe LJJ concurring) observed that Foakes v Beer[1] precluded any variation of the agreement to repay the debt without good consideration, despite the recent decision in Williams v Roffey Bros Ltd. Peter Gibson LJ stated that ‘it is clear… that a practical benefit of that nature is not good consideration in law’.
But that was a matter expressly considered in Foakes v Beer yet held not to constitute good consideration in law.