In some of the cases in which it is said that extrinsic evidence is inadmissible to contradict the recital of a valuable consideration in a contract so as to render it inoperative in law, the contract was under seal.1 Contracts of this sort are governed by principles different from those which apply to simple executory contracts. At common law in the classic period a contract under seal was valid and enforceable without a valuable consideration.2

23 Schneider v. Turner, 130 111. 28, 6 L. R. A. 164, 22 N. E. 497.

24 United States Light & Heating Co. v. J. B. M. Electric Co., 189 Fed. 382.

25Drury v. Fay, 31 Mass. (14 Pick.) 326. (Possibly C's forbearance to sue was the consideration in this case.)

26Wellmaker v. Wheatley, 123 Ga. 201, 51 S. E. 436.

27Eggleston v. Pantages, 93 Wash. 221, 160 Pac. 425.

28 See ch. LXIX.

29 See ch. LXIX.

11llinois Central Insurance Co. v. Wolf, 37 111. 355.

2 See Sec. 1166.