Court case[1919] 2 KB 571

Mr Balfour, a civil servant in Ceylon, promised his wife, who stayed in England for health reasons, an allowance of 30 pounds a month. The couple later separated and the wife sued to enforce the promise.

The Court of Appeal held that agreements between husband and wife about household allowances are not contracts because the parties do not intend them to have legal consequences. Such arrangements are outside the realm of contracts altogether; the consideration was natural love and affection, not a bargain.