Under this head are to be considered inadequacy of consideration, illegal contracts, and contracts against public policy.

Inadequacy of consideration is never ground in itself for equitable relief, unless it is so gross as to shock the conscience. Or, unless, in the words of Lord Thurlow,3 it is "an inequality so strong, gross and manifest, that it must be impossible to state it to a man of common sense without producing an exclamation at the inequality of it."

Inadequacy of consideration, however, will be taken into consideration, with other inequitable incidents, such as undue influence, concealment, etc.4

Equitable relief will be granted in those illegal contracts, where the parties are not considered as standing in pari delicto. Equity will never aid a person to obtain advantage of his own wrongful conduct, and where the parties are equally guilty, equity, like the common law, will leave the parties as she finds them.

3 In Gwynne vs. Heaton, 1 Brown Ch., 159. 4 Fish vs. Leser, 69 I11., 394;

Graffon vs. Burgess, 117 U. S., 184.

The various classes of illegal contracts, and cor-tracts against public policy, have been discussed under the subject of contracts.5