duress which are to be considered in a later chapter. Moreover, whether or not a promise has been voluntarily given also raises issues of public policy which will be considered in more detail in this chapter. In North Ocean Shipping Co v Hyundai Construction Co, a shipbuilding

If I am right in the conclusion reached with some doubt earlier that there was consideration for the 10% increase agreement reached at the end of June 1973, and it be right to regard this as having been reached under a kind of duress in the form of economic pressure, then what is said in Chitty on Contracts, 24th edn, 1977, Vol 1, para 442, p 207, to which both counsel referred me, is relevant, namely, that a contract entered into under duress is voidable and not void:

On the other hand, the findings of fact in the special case present difficulties whether one is proceeding on the basis of a voidable agreement reached at the end of June 1973, or whether such agreement was void for want of consideration, and it were necessary in consequence to establish that the payments were made involuntarily and not with the intention of closing the transaction.