“…anced on reasonable grounds which he believed to have a fair chance of success must amount to consideration. Moreover, it can be seen from Simantob v Shavleyan [2019] EWCA Civ 1105 that forbearance of a defence that is later held to have had no real prospect of success under the test in Swain v Hillman [2001] 1 All ER 91 is capable of amo…”