First of all there is the consideration of the past. Past consideration is defined as consideration given in exchange after performing the act. The act performed is autonomous. Two parties were not connected to each other until the contract was made. The above considerations are valid under Malaysian law. The phrase “done or refrained from doing” shows that past considerations exist. For example, Rama saved Kiri's son from drowning in the pool. Kiri promised to reward Rama RM500. This shows that Rama's deed is past and the promise was made after the deed. Therefore, this illustration is passed