 As mentioned above, the standard critique of the act utilitarian theory of promissory obligations is that it doesn’t accord with our intuitive judgment that at least some promises that don’t produce the maximum utility still ought to be kept. In claiming that utilitarianism has unacceptably counter-intuitive results in certain cases, this argument it is of a piece with most arguments against the view. One sort of counter-intuitive case that has received some attention is the so-called “Desert Island” case, where a promise is made in isolation (on a desert island) to someone who then dies. The question is whether there is any obligation to keep the promise, given that the promisee can’t have any expectations of its fulfillment (being dead) and that no-one else can know of the promise (see Nowell-Smith 1956; Narveson 1963: 210; Cargile 1964; Narveson 1967: 196–7). See the section on  Problematic Promisees and the Uptake Condition (§5.1]  above for more information.