In the case of Williams v Roffey Brothers (1990) it raises a lot of controversy. In the case involving the defendants who were the main contractors of a construction site, he also realizes that the subcontractor carpenters who are having financial difficulties and threaten the subcontractor by not completing the work. To ensure that the plaintiffs completed the work on time, the defendants offered them additional payments. This is because a fine would have been imposed on the defendants just because if the works were not completed within the stipulated time. The offer was accepted but when payments were not required the appellants sued for the payments. It was held that the plaintiff was entitled to the sum of money because the subcontractors were in financial difficulty and the defendants obtained a benefit from the work of the subcontractors. They wouldn't have to pay the penalty clause. The case contributed to criticism of the doctrine of consideration, according to which only unilateral contract modifications must involve the modification “same for more,” but not “less for the same” (Atiyah,