In an action to cancel a five-year lease, it appeared that the lessee had agreed to pay as rent an amount equal to one cent a gallon on each gallon of gasoline delivered, by it, on the leased premises. Held, that the lease was valid, as it created a bilateral contract supported by consideration on both sides, since according to the court's construction of the lease the lessee had impliedly promised to use the premises as an automobile filling and service station for the stipulated period and so would necessarily be required to deliver gasoline there. Jackson v. Pepper Gasoline Co., 280 Ky. 226, 133 S. W. (2d) 91 (1939).
James A. Lee,
LANDLORD AND TENANT - NECESSITY FOR CONSIDERATION FOR LEASE,
Mich. L. Rev.
Available at: https://repository.law.umich.edu/mlr/vol39/iss2/20