If the debt is paid in something other than that stipulated for in the contract, but accepted in lieu thereof, such change in medium of payment amounts to a consideration.1

The check of the debtor is merely the usual and customary means of paying money, and it should not have any greater legal effect than if the same amount had been paid in money. Accord-ingly, is held that payment by check is not a different method of payment from that contemplated in a contract for the payment of money; and a smaller sum is not consideration for the discharge of a large sum by reason of the fact that such smaller sum is paid by check.2 In some jurisdictions, however, it has been said that payment by check is so different from payment in cash, being rather payment by an inland bill of exchange,3 that such payment is consideration for the creditor's promise to accept a lesser sum in satisfaction of a larger sum.4 Such payment has been upheld as consideration on the theory that payment by a chattel and payment in money should have the same legal consequences,5 which practically amounts to a denial of the rule itself.