... Trees House Ltd. after departing from the Pinnel-Doctrine. However sometimes estoppel may be used to create a new cause of action so for example Charles Rickards v Oppenhaim. Here one might say, that estoppel might have been used as a sword. The strict common law rule is that a promise in addition to pre-existing legal relation is not enforceable if there is no consideration. This is exemplified in the Pinnel's Case in which Lord Coke laid down that a payment of the debtor to the creditor of a lesser sum on the due day in satisfaction of the greater original sum cannot be consideration for the whole. This despite the creditor promised to relieve the debtor from the rest of the debt, the creditor is not bound by this settlement. He can sue the debtor the next day for the balance outstanding. The Pinnel-Doctrine has been reiterated by the House of ...

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