*234.* _Individual Promise, Subscriptions, Signature._—An individual promise to give a donation to charity, can not be enforced.(415) But subscriptions to build a church or other charitable institution or to pay the salary of a clergyman when signed by more than one person, have been held binding in some cases on the disputed rule of a-promise-for-a-promise consideration.(416) In the foregoing cases the donor might revoke his subscription or in case of his death his estate would not be liable.(417) However, when expenses have been made or steps taken in the carrying out of the object of the subscriptions, the general rule is that the subscriptions become binding contracts.(418) If the object of the subscriptions be abandoned or changed without the consent of the subscriber, he is thereby released. A promissory note given for the subscription, unless negotiated for value in due course of trade, does not change the foregoing rules.(419) Where many persons subscribed to build a church and some of them failed to pay, one who paid brought an action on behalf of himself and others and collected the unpaid subscriptions.(420) The defendant Nalty signed “Nalty Family, $1,000,” but he was held personally liable.(421) *235.* _Special Purpose, Suit._—When money is subscribed for a special purpose, as for rebuilding a church, it belongs to the church organization; and in a suit to recover the money the action should be brought in the name of the corporation, if incorporated, and if not incorporated it should be brought in the name of the interested party.(422) *236.* _Promise, Consideration._—A promise made by the owner of land to a trustee for the benefit of a religious society, that he would convey the land to such society if it would build a church thereon, is a good and lawful consideration; and after work was begun on the church, the contract was enforceable in a court of equity.(423) CHAPTER XX. PEWS *237.* _Sold, Rented._—Prior to the Reformation pews were not sold nor rented and every member had the right to sit wherever he pleased in the body of the church. After the Reformation, the ordinary or bishop was granted the right of “faculty” to rent or sell pews.(424) *238.* _Incorporeal Hereditament._—The English title in a pew is in the nature of a right of way through another’s land; it is an incorporeal hereditament. In the absence of express law, the title to pews in this country is said to be in the nature of real estate, and in fact not very different from the English title.(425) In some States the title is made personal property by statute.(426) And in others the courts have inquired into the law of the church and adjudged the title accordingly.(427) The general rule is that the owner of a pew simply has an easement.(428)