In a contract of insurance, as in all other contracts, there must be a consideration from both parties to contract. In the case of Phoenix Life Insurance Co. vs. Roddin,3 the Supreme Court of the United States discussed the subject of consideration in insurance contracts as follows:

"But the 'consideration,' in the legal sense of the word, of a contract, is the quid pro quo, that which the party to whom a promise is made does, or agrees to do, in exchange for the promise. In a contract of insurance, the promise of the insurer is to pay a certain amount of money upon certain conditions; and the consideration on the part of the insured is his payment of the whole premium at the inception of the contract, or his payment of part then, and his agreement to pay the rest at certain periods while it continues in force. In the present case, at least, the application is collateral to the contract, and contains no promise or agreement of the assured. The statements in the application are only representations upon which the promise of the insurer is based, and conditions limiting the obligation which he assumes. If they are false, there is a misrepresentation, or a breach of condition, which prevents the obligation of the insurer from ever attaching, or brings it to an end, but there is no breach of any contract or promise on the part of the assured, for he has made none. In short, the statements in this application limit the liability of the insurer, but they create no liability on the part of the assured. The expression at the beginning of the policy, that the insurance is made 'in consideration of the representations made in the application for this policy,' and of certain sums paid and to be paid for premiums, does not make those representations part of the consideration, in the techincal sense, or render it necessary or proper to plead them as such."

1 Wiebeler vs. Milwaukee Mechanics Mutual Ins. Co., 30 Minn., 464.

2 Woodruff, Cases on Insurance, p. 79. 120 U. S., 183.