Re McArdle (1951) demonstrated that past consideration is not valid consideration. In this case, renovations were completed before an agreement to pay was signed, rendering the promise unenforceable. It underscored the principle that consideration must be contemporaneous with the promise.
Past Consideration: The case established that past consideration, or acts performed before a promise is made, cannot constitute valid consideration for a contract. This principle ensures that agreements are made with mutual obligations in mind at the time of the contract.
