On principle there is a difference between the validity of a new promise made after action brought where the defence is infancy, and where the defence is the Statute of Limitations or bankruptcy, since in the latter cases prior to the new promise there is not even a voidable obligation. An infant's promise is valid until repudiated.84 Accordingly a right of action exists against him at the time the action is brought, even though no new promise has been made. The effect of the new promise is merely to defeat the defence of infancy if it is pleaded. This view is accepted by some of the decisions and a new promise is held sufficient though made after begining of the action.85 But other decisions based in the main on an early English case decided before the nature of an infant's obligation was fully understood hold that the new promise in order to be effective must be made before action brought.86 Where, however, the obligation is barred by the Statute of Limitations, it is in reality the new promise which is the basis of the creditor's right.87 Accordingly until the new promise is made, no right of action exists in favor of a creditor whose claim is barred. The courts, therefore, now generally hold a new promise, after action brought, insufficient.88 The same reasoning is involved where a discharge in the bankruptcy is concerned. Here also a promise after action brought is insufficient.89