Past consideration is above all else. Past consideration is defined as consideration given in return after the act has been performed. The act performed is independent. Two parties were not bound to each other until the contract was formed. The consideration passed is valid under Malaysian law. The expression “does or refrains from doing” shows that a past consideration exists. For example, Rama saved Kiri's son from drowning in the swimming pool. Kiri promised to reward Rama RM 500. This shows that Rama's deed has passed and the promise is made after the deed. Therefore, this illustration has passed