In this paper, we study the onset of cellular convection in a horizontal fluid layer heated from below, with a free-slip boundary condition at the bottom when the driving mechanism is surface tension at the upper free surface, in the light of the modified analysis of Banerjee et al. (Jour. Math. & Phys. Sci., 1983, 17, 603). This leads to a formulation of the problem which depends upon whether the liquid layer is relatively hotter or cooler. It is found that the phenomenon of surface tension driven instability problems should not only depend upon the Marangoni number which is proportional to the maintained temperature differences across the layer but also upon another parameter that arises due to variation in the specific heat at constant volume on account of the variations in temperature. Numerical results are obtained for the problem wherein the lower free boundary is perfectly thermally conducting.