As in the case of contracts generally,1 a valuable consideration is an essential element of a valid accord and satisfaction.2

11 Day v. McLea, 22 Q. B. Div. 610 (probably a case of want of consideration). [See, Hirachand Punamchand v. Temple (1911), 2 K. B. 330]; Rosen-field v. Fortier. 94 Mich. 29, 53 N. W. 930; Krauser v. McCurdy, 174 Pa. St. 174, 34 Atl. 518.

12 See Sec. 596 and 619.

1 McGinnis v. McGinnis, 274 Mo. 285, 202 S. W. 1087.

2 McGinnis v. McGinnis, 274 Mo. 285, 202 S. W. 1087.

3Lantry Contracting Co. v. Atchison Topeka & Santa Fe Ry. Co., 102 Kan. 709. 172 Pac. 527.

4Gross v. Allen, 182 Ia. 429, 165 N. W. 993.

5 Gross v. Allen, 182 Ia. 429, 165 N. W. 993.

1See Sec. 537 et seq.

2 England. Fitch v. Sutton, 5 East 230; Foakes v. Beer, 9 App. Cas. 605.

Alabama. Scott v. Rawls, 150 Ala. 399, 48 So. 710.

Since from the nature of the transaction, there is, on the one hand, a pre-existing liability of some sort either existing or at least asserted by one of the. parties, and on the other, something of value given or promised in satisfaction of such liability, a valuable consideration is always present, except in cases in which the claim is for money or for something the value of which is fixed by law in money, and the thing given or promised in satisfaction of such claim is money, or something the value of which is fixed by law in money.3 As these questions have already been discussed in connection with the general doctrine of consideration,4 it is necessary here merely to refer to them to show their application to accord and satisfaction.