matter which is an equitable chose in action, then there is no reason in principle or in authority why the donee should not take the benefit just as much as he will if the giver gives him a pound note and puts it in his hand. Since the transaction is thus perfect, the question of consideration becomes irrelevant, for consideration is only necessary to support the assertion of a right to have made perfect something which is not yet perfect
› for example, a contractual right.
Jenkins LJ similarly observed at (676
› 7) that:
I am further prepared to accept the proposition that an equitable assignment of an existing interest in property of a character capable of being assigned may be a valid and binding assignment notwithstanding that it is made voluntarily
› that is to say, notwithstanding that it has no consideration to support it and is in the nature of a mere gift ...
