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This case (Re mc cardle [1951] Ch 669) is the archetypal example of a past benefit being unacceptable as Consideration in a Contract. The occupants of a house carried out certain improvements during their tenancy, and were offered payment in recompense by the owner. However, the owner died before doing so, and his representatives refused to honour the promise. The courts supported the owner's representatives, because the tenants had not provided good consideration.

Note that in this case the tenants' work was carried out at their own behest, and not at the request of the owner. Had the owner explicitly requested the tenants to do the work, and then offered payment, the court may have been able to use the doctrine of Implicit assumpsit to incorporate the past work into the agreement, and thereby deem it consideration.