... at this stage the reason for the promise being binding,"3 However, Atiyah is also arguing this is still the main function of consideration, a more controversial view, which relies on examination of more recent and better recorded cases. The idea of consideration was left unchallenged throughout the 17th and the first half of the 18th centuries, but was attacked as an emerging doctrine by Lord Mansfield's attempt to abolish it as a requirement for a contract. This was repelled by the case of Rann v Hughes (1778)4, which explicitly maintained the need for consideration in simple contracts as essential to their enforceability. This seems to be the first chance the courts had to abandon consideration in favour of some other reason to enforce a promise, such as evidence of the intention to be bound, and proves that consideration was becoming more firmly fixed as a discrete and identifiable part of an enforceable promise, ...

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