LandmarkHouse of Lords(1884) 9 App Cas 6051 Jan 1884· Contract
Foakes v Beer established the rule that payment of a smaller sum cannot satisfy a debt of a larger sum, even if the creditor agrees to accept the lesser amount. This case affirmed the rule in Pinnel's Case that part payment of an existing debt is not good consideration, and confirmed the general rule that an accord without satisfaction is unenforceable.