While a consideration is a necessary element of every contract, it is not necessary that each separate promise or covenant should have a distinct consideration. If there is but one consideration offered in return for several promises, and it is accepted for them together, it will support them.1 This principle is often invoked in questions

11 "It is further insisted, that an executory promise, not founded upon any valuable consideration, is a mere nude pact, furnishing no grounds for an action at law, and that performance of such a promise will not be enforced in equity. This is true so long as the promise has no consideration. Anything that may be detrimental to the promissee or beneficial to the prom is-sor in legal estimation will constitute a good consideration for a promise. Expenditures made upon permanent improvements upon land with the knowledge of the owner, induced by his promise, made to the party making the expenditure, to give the land to such party, constitute in equity a consideration for the promise." Freeman v. Freeman, 43 N. Y. 34.

12Ricketts v. Scothorn, 57 Neb. 51, 73 Am. St. Rep. 491, 42 L. R. A. 794, 77 N. W. 365.

1 United States. S. Jarvis Adams Co. v. Knapp, 121 Fed. 34.

Arkansas. Johnson v. Wilkerson, 96 Ark. 320, 131 S. W. 690.

Colorado. Irwin v. Locke, 20 Colo. 148, 36 Pac. 898.

Illinois. Marske v. Willard, 169 111. 276, 48 N. E. 290 [affirming, 68 111. App. 83]; Hills v. Hopp, - 111. - , 122 N. E. 510.

Indiana. Souffrain v. McDonald, 27 of mutuality of obligation.2 If A gives value for two or more promises from B, B can not claim that one of such promises was not supported by consideration, though the parties have not apportioned the consideration to the separate promises.3 If A enters into a contract with B by the terms of which B agrees to repay to A the consideration which A has paid to B under such contract if A thereafter enters into another specified contract, such promise on the part of B is enforceable.4 A purchase of railroad bonds is

Ind. 269; Eisel v. Hayes, 141 Ind. 41,

40 N. E. 119; Koh-i-moor Laundry Co. v. Lockwood, 141 Ind. 140, 40 N. E. 677.

Iowa. 3oyd v. Watson, 101 la. 214, 70 N. W. 120.

Kansas. Carlisle v. Farmers' Elevator & Business Association, - Kan. - , 180 Pac. 280.

Kentucky. Queen City Coal Co. v. Ry. (Ky.), 44 S. W. 103; Montanus v. Buschmeyer, 158 Ky. 53, 164 S. W. 802.

Maryland. Maughlin v. Perry, 35 Md. 352.

Minnesota. Kronschnabel-Smith Co. v. Kronschnabel, 87 Minn. 230, 91 N. W. 892.

Missouri. Drummond Realty & Investment Co. v. W. H. Thompson Trust Co. (Mo.), 178 S. W. 479.

Montana. Rose v. Northern Pacific Ry. Co., 35 Mont. 70, 119 Am. St. Rep. 836, 88 Pac. 767.

Nebraska. Lyman v. Lincoln, 38 Neb. 794, 57 N. W. 531; Doll v. Crume,

41 Neb. 655, 59 N. W. 806; Boughn v. Smith, 58 Neb. 590, 79 N. W. 160.

New Jersey. Wallace v. Leber, 65 N. J. L. 195, 47 Atl. 430; Flack v. Con-dict, 66 N. J. L. 351, 49 Atl. 508.

North Carolina. Kramer v. Old, 119 N. Car. 1, 56 Am. St. Rep. 650, 34 L. R. A. 389, 25 S. E. 813.

Ohio. Wetzell v. Richcreek, 53 O. S. 62, 40 N. E. 1004; King v. King, 63 O. S. 363, 81 Am. St. Rep. 635, 52 L. R. A. 157, 59 N. E. 111.

Oregon. House v. Jackson, 24 Or. 89, 32 Pac. 1027.

Texas. Missouri, etc., Ry. v. Carter, 95 Tex. 461, 68 S. W. 159.

Washington. Frank v. Jenkins, 11 Wash. 611, 40 Pac. 220.

2 See Sec. 566.

3 United States. Franklin Telegraph Co. v. Harrison, 145 U. S. 459, 36 L. ed. 776; Mississippi River Logging Co. v. Robson, 69 Fed. 773, 16 C. C. A. 400.

Arkansas. St. Louis Southwestern Ry. Co. v. Haynie, 120 Ark. 26, 179 S. W. 170.

Colorado. Gibbs v. Wallace, 58 Colo. 364, 147 Pac. 686.

Illinois. Bates Machine Co. v. Bates, 192 111. 138, 61 N. E. 518.

Kansas. Carlisle v. Farmers' Elevator & Business Association, - Kan. - , 180 Pac. 280; Bank v. Rowlinson, 2 Kan. App. 82, 43 Pac. 304.

Kentucky. Fairbanks v. Tafel, 159 Ky. 602, 167 S. W. 887.

Maryland. Ziehm v. Frank Steil Brewing Co., 131 Md. 582, 102 Atl. 1005.

Michigan. Sax v. Ry., 125 Mich. 252, 84 Am. St. Rep. 572, 84 N. W. 314.

Montana. Rose v. Northern Pacific Ry. Co., 35 Mont. 70, 119 Am. St. Rep. 836, 88 Pac. 767.

Oregon. House v. Jackson, 24 Or. 89, 32 Pac. 1027.

Pennsylvania. Philadelphia Ball Club v. Lajoie, 202 Pa. St. 210, 90 Am. St. Rep. 627, 58 L. R. A. 227, 51 Atl. 973.

West Virginia. Rhoades v. R. R., 49 W. Va. 494, 87 Am. St. Rep. 826, 55 L. R. A. 170, 39 S. E. 209.

4 Turner v. Frazier, 157 Ky. 388, 163 S. W. 245.

a consideration for a promise of such railroad to ship by a certain connecting road.5 The purchase price is not only consideration for a sale, but also, if so agreed upon, for a warranty,6 or for a promise not to compete in business,7 or for a promise to secure certain additional business to the purchaser,8 or for a promise to repurchase,8 or for a promise not to sell the articles purchased without giving the original seller an opportunity to buy,10 or for a promise to reconvey,11 or to renew the contract,12 or to sell an additional tract of land at a stipulated price,13 or to repay such amount of duty in excess of a given amount as should be collected by the United States,14 or for a promise by the vendee to pay to the vendor the profits realized in case of a subsequent sale,18 or to accept payment in notes of a third person and to indemnify the purchaser against liability on his indorsement of such notes.18 A sale of land is a consideration for covenants to pay therefor and not to engage in a certain business.17 A's acceptance of a deed from C passing title and A's payment of the purchase price therefor, and B's receipt of commissions for effecting such sale, form a consideration for B's promise to repay to A the purchase price if B was unable to sell the property for A at such price in a certain time.18 A contract whereby a city agrees to approve a certain plat and to certify it and to grade certain streets, in consideration of which the property owner agreed to pay a certain sum of money, is valid, although the city was legally bound to approve such plat and to certify it.19 Under a contract by which a town agrees to pay a water company for a supply of water, and the water company agrees to furnish water, to sell its water-works to the town on demand and to permit an inspection of its books, the covenant for inspection of books is supported by a valuable consideration, although no corresponding right was conferred upon the water company.20 A promise by a water company to furnish surplus water at a certain price is a lease, which by implication contains a covenant for quiet enjoyment, and thus precludes the promisor from doing any act to interfere with the use of the surplus water by the adversary party. Such covenant of quiet enjoyment is accordingly a sufficient consideration, although the promisor is not bound to keep his canal in repair or incur any expense; and such promisor is not bound to do anything to secure such surplus water.21 A promise to furnish board to non-union men at a certain price is a sufficient consideration for a promise by their employer to furnish a certain number of boarders for a certain time and to pay a certain price therefor.22 A contract entered into as part of the original contract of employment, that the employer might, if he chose, deduct from the wages of employe the amount due from him to third persons for board and lodging, and pay to the creditor of the employe, is supported by sufficient consideration.23