Under the name of duress, there have long been included what early lawyers classified under the two headings: (1) duress - that is, imprisonment - and (2) menaces, that is, threats of imprisonment or bodily harm. Unlike the defence of fraud, duress was early recognized by the common-law courts as a ground for avoiding a sealed instrument, then the only form of contract.1 Bracton states that a deed made under such fear as may happen to a resolute man because of danger of death or torture of the body invalidates the conveyance.2 Coke,3 says that a man shall avoid his own act for menaces in four cases: "1. for fear of losse of life, 2. of losse of member, 3. of mayhem, and 4, imprisonment; otherwise it is for fear of battery, which may be very light, or for burning of his house, or taking away, or destroying of his goods, orthe like, for there he may have satisfaction by recovery of damages;" and these are the limits stated in subsequent early authorities,4 (though with some doubt as to the sufficiency of a mere threat of imprisonment),5 and they are still not without influence in the law. It will be observed that threat of an ordinary battery is not included in Coke's list, and Blackstone says: "A fear of battery or of being beaten, though never so well grounded, is no duress."6