The word "consideration" is used to denote two different ideas. The valuable consideration, which is, for practical purposes, the consideration in the law of contracts, will be discussed later.1 The good consideration consists of natural love and affection, which in law is equivalent to ties of blood or marriage, as between husband and wife,2 or between one and his lineal de-scendants as children,3 or grandchildren.4

Technical love and affection were held not to exist between those who are related collaterally by consanguinity,5 such as a brother6

7 N. H. 549, 28 Am. Dec. 372; Frye v. Hubbell, 74 N. H. 358, 68 Atl. 325.

New Jersey. Corle v. Monkhouse, 50 N. J. Eq. 537, 25 Atl. 157.

Ohio. Dalrymple v. Wyker, 60 O. S. 108, 53 N. E. 713.

Oregon. Rector v. Wood, 24 Or. 396, 41 Am. St. Rep. 860, 34 Pac. 18.

Rhode Island. Darcey v. Darcey, 29 R. I. 384, 71 Atl. 595.

Utah. Utah National Bank v. Nelson, 38 Utah, 169, 111 Pac. 907.

Washington. Tindall v. Northern Pacific Ry. Co., 58 Wash. 118, 107 Pac. 1045.

West Virginia. Rutherford v. Rutherford, 55 W. Va. 56, 47 S. E. 240.

27 "A test of * * * consideration is whether the promisee at the instance of the promisor has done, forborne, or undertaken to do anything real, or whether he has suffered any detriment or whether in return for the promise he has done something that he was not bound to do, or has promised to do some act or has abstained from doing something." Presbyterian Board of Foreign Missions v. Smith, 209 Pa. St. 361, 58 Atl. 689.

28See Sec. 542 et seq.

1 See Sec. 522 et seq.

2 Dunbar v. Dunbar [1909], 2 Ch. 639; Smith v. Smith, 80 Ark. 458, 97

S. W. 439; Brown v. Brown, 44 S. Car. 378, 22 S. E. 412.

3 England. Jennings v. Selleck, 1 Vern. 467.

Illinois. Oliphant v. Liversidge, 142 111. 160, 30 N. E. 334.

Iowa. Schneitter v. Carman, 98 la. 276, 67 N. W. 249 (and including the spouses of such children).

New Hampshire. Bell v. Scammon, 15 N. H. 381, 41 Am. Dec. 706.

Missouri. Hutsell v. Crewse, 138 Mo. 1, 39 S. W. 449.

Pennsylvania. Ferguson's Appeal, 117 Pa. St. 426, 11 Atl. 885 (including step-children); Carney v. Carney, 196 Pa. St. 34, 46 Atl. 264. (A conveyance by a child to a parent may be based on love and affection and past support.) Carney v. Carney, 196 Pa. St. 34, 46 Atl. 264.

4 Hanson v. Buckner, 34 Ky. (4 Dana) 251, 29 Am. Dec. 401.

Contra, Borum v. King, 37 Ala. 606.

5Buford v. McKee, 31 Ky. (1 Dana) 107.

6 Camden v. Bennett, 64 Ark. 155, 41 S. W. 854; Harris v. Mclntyre, 118 111. 275, 8 N. E. 182.

Contra, Candee v. Connecticut Saving Bank, 81 Conn. 372, 71 Atl. 551; Printup v. Patton, 91 Ga. 422, 18 S. E, 311.

or a nephew,7 though a conveyance to a cousin has been upheld as being on valuable consideration.8 Technical love and affection do not exist between those who are related collaterally by affinity.9 Thus love and affection for the wife of promisor's dead brother are not sufficient consideration for a promissory note, even in a jurisdiction in which it is said that a good consideration is sufficient.10