Past consideration means consideration which has already moved before the formation of an agreement. Past consideration is valid only if it is given by the promisee at the desire of the promisor.

Example 1: A teaches the son of B at B’s request in the month of January, and in February B promises to pay A a sum of ₹5,000 for his services. The services of A will be past consideration. In case of past voluntary services, person has acted voluntarily and not at the request of the promisor. Say for example, A finds B’s purse and gives it to him. B promises to give A ₹500 as reward. It is a valid contract. B is compensating A for A’s past voluntary services