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In this widely-cited case (Foakes v Beer [1884] 9 App Cas 605) the House of lords supported the view that that part-payment of debt could not be used as consideration to support a contract. This principle was already known from the Court of Appeal ruling in Pinnel's case, but this House of lords decision gave it additional strength.

Foakes owed Beer a sum of about £2000, awarded in damages from an earlier case. The parties agreed that if Foakes paid £500 at once and the rest of the sum by installments, then Beer would not take legal action. Foakes eventually paid the debt, but not the interest, which would have accrued since the date the award was made. Beer sued Foakes for the interest. In defence, Foakes claimed that the new agreement (payment of the sum in installments) cancelled the original obligation, and the Beer had thereby waived her right to the interest. Beer claimed that the agreement was void since Foakes offered no consideration. The Court sided with Beer, allowing Pinnel's case to stand.