In the case of Williams v Roffey Brothers (1990), it causes a lot of controversy. The case involved the defendants who were the main contractors on a construction site, it also finds that subcontractor carpenters who are in financial difficulties threaten the subcontractor by not completing the work. To ensure that the plaintiffs completed their work on time, the defendants offered them additional payments. In fact, the accused would have been punished simply because the work was not completed on time. The offer was accepted, but when payments were not requested, the plaintiffs took legal action to obtain the payments. It was held that the plaintiff was entitled to this sum of money because the subcontractors were experiencing financial difficulties and the defendants had actually benefited from the subcontractors' work. They would not have to pay the penalty clause. This case contributed to criticisms of the doctrine of consideration, according to which only unilateral contractual modifications must involve "the same for more", but not "less for the same" (Atiyah,