The original common-law rule seems to have been that duress per minas could exist only when the threat was of loss of life, limb or liberty.1 This was part of the old theory that duress was to be tested by the nature of the act or threat, without reference to the effect thereof on the mind of the person subjected thereto,2 and that to be duress the act in question must be such as could affect a brave, or at least a reasonably firm man.3 The modern tendency being to discard such tests, the modern rule as to what threats may amount to duress includes much more than the original rule did.4