Eastwood v Kenyon (1840) established that past consideration is not valid for enforcing a promise. The case involved John Eastwood, who raised Sarah Kenyon and incurred debts for her benefit, only to be denied repayment by her husband after her marriage.
Past Consideration Isn't Enough: Eastwood spent money improving property before any promise to repay. The court ruled this past action wasn't sufficient consideration to enforce a later repayment promise by the owner.
