sentences:  The doctrine of consideration is irrelevant in many jurisdictions, although contemporary commercial litigant relations have held the relationship between a promise and a deed is a reflection of the nature of contractual considerations.If there is no element of consideration found, there is thus no contract formed.However, even if a court decides there is no contract, there might be a possible recovery under the doctrines of "quantum meruit" (sometimes referred to as a quasi-contract) or promissory estoppel.