Consideration uncertain in amount- whether question of inadequacy is thereby excluded.

(g) White v. Damon, 7 Ves. 30, 35; Ex parte Latham, ibid, 35, n.; Borell v. Dann, 2 Ha. 450; supra, 357, n. (c).

(h) Anon. cited 6 Ves. 24; and see Knight v. Majoribanks, 11 Beav. 322; affirmed. 2 Mac. & G. 10.

(i) Sug. 311; citing Pope v. Roofs, 1 Bro. P. C. 370; Mortimer v. Capper, 1 Bro. C. C. 156; and Jackson v. Lever, 3 Bro. C. C. 605.

(k) Bower v. Cooper, 2 Ha. 408.

(l) Coles v. Trecothink, 9 Ves. 246; Kenney v. Wexham, 6 Mad. 355.

(m) Per Lord Tottenham, C, in Davies v. Cooper, 5 Myl. & C. 279.

We have already considered (n) those cases in which the Court has, upon the mere ground of inadequacy of consideration, set aside sales of reversionary interests, even after the conveyance has been executed: these cases, of course, are, a fortiori, authorities in favour of a defendant resisting specific performance. A degree of inadequacy which might be insufficient to induce the Court to interfere and set aside an executed contract, would, it is conceived, be a valid defence in such a suit (o): especially if the contract has not been acted on or attempted to be enforced until the reversion has fallen into possession (p).

We have already seen that where the estate is sold for a contingent consideration, e. g., a life annuity, the occurrence of the contingency is, in general, no defence to the purchaser's suit for specific performance (q).

So, on the other hand, it has been held that the mere excessive amount of the purchase-money, (even although not attributable to fraud, misrepresentation, or concealment on the part of the vendor), is a defence available to a purchaser (r): and Sir E. Sugden remarks that "few contracts can be enforced in Equity where the price is unreasonable, because contracts are not often strictly observed by either party: and if an unreasonable contract be not performed by the vendor, according to the letter in every respect, Equity will not compel a performance in specie "(s).

It is, however, submitted, that such a defence by a pur-chaser deserves but little favour in a Court of Equity: there is a great difference between proofs of inadequacy and of excess of price. Inadequacy can be ascertained by reference to an extrinsic standard; viz., the general market value of similar property; and there is no difficulty in comparing money with money: but the Court when required to pronounce a price excessive, is called upon to do what it has, apparently, no satisfactory means of doing; viz., to determine what represents the money value, to a specified individual, of a specified estate: there is no extrinsic standard by which such value can be certainly determined. The mere fact of the contract having been entered into, knowingly and bond fide, may, it is conceived, be not unreasonably considered in itself to determine the real value of the estate, to the purchaser, at the time of the contract; whatever may be its value to third persons, and however much its value to the purchaser himself may have been altered by subsequent events (t).