<Ul> <Li> Chappell & Co Ltd v Nestle Co Ltd, Lord Somervell, "A contracting party can stipulate for what consideration he chooses . A peppercorn does not cease to be good consideration if it is established that the promisor does not like pepper and will throw away the corn ." </Li> </Ul> <Li> Chappell & Co Ltd v Nestle Co Ltd, Lord Somervell, "A contracting party can stipulate for what consideration he chooses . A peppercorn does not cease to be good consideration if it is established that the promisor does not like pepper and will throw away the corn ." </Li> <P> A promise cannot be based upon consideration that was said, given or done before the promise was performed . Something said afterwards, will not count as consideration . For example, if X promises to reward Y for an act that Y had already performed then while the performance of that act is good consideration, for the promise to be rewarded for it is past consideration and therefore not good consideration . </P> <P> In Eastwood v Kenyon the guardian of a young girl raised a loan to educate the girl and to improve her marriage prospects . After her marriage, her husband promised to pay off the loan . It was held that the guardian could not enforce the promise as taking out the loan to raise and educate the girl was past consideration, because it was completed before the husband promised to repay it . </P>

What is meant by past consideration in contract law
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