Transcript for:
Understanding Contract Consideration in Law

Title: Business Law (LAW1013)

URL Source: blob://pdf/3188a64b-4118-49c2-83da-34e53df1d572

Markdown Content: BUSINESS LAW

TOPIC 4:

ELEMENTS OF CONTRACT

(PART 2)

  • CONSIDERATION

PREPARED BY: ABIGAIL C. C.

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rights reserved.

BLAW / LAW2013 REV 00

01/08/2017 Section 2(d) of Contract Act 1950

when, at the desire of the promisor , the promisee or

any other person has done or abstained from doing,

or does or abstains from doing, or promises to do or

to abstain from doing, something, such act or

abstinence or promise is called a consideration for the

promise .

ELEMENTS OF CONTRACT:

  1. Consideration

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Consideration is value for a promise .

When someone is willing to give value for a promise,

it shows that he takes the deal seriously and intends

to be bound by it .

Consideration comes in many forms .

It need not be quantified in terms of money .

For example : your willingness to stop from doing

something or give up something can constitute

consideration .

ELEMENTS OF CONTRACT:

  1. Consideration

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ELEMENTS OF CONTRACT:

  1. Consideration

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Wong Hon Leong David v Noorazman Bin Adnan

[1995] 3 MLJ 283

Appellant promised to pay RM 268 ,888 if the respondent assist him in

obtaining the approval for the application to convert and subdivide

certain land to be developed into housing estate .

The Respondent promise that he would assist the Appellant .

Judgment:

The exchange of mutual promises was a good consideration .

There was a binding agreement between them and the Respondents

claim for the fee succeeded .

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ELEMENTS OF CONTRACT:

  1. Consideration

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ISSUES RELATED TO CONSIDERATION

  1. Consideration Need Not be Adequate

  2. Past consideration is Good Consideration

  3. Natural Love and Affection is Valid Consideration

  4. Accord and Satisfaction Part Payment may

Discharge an Obligation

  1. Consideration Need Not Move from the Promisee

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ELEMENTS OF CONTRACT:

  1. Consideration

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Explanation 2 to Section 26 of CA 1950:

An agreement is not void merely because the consideration is

inadequate .

Illustration (f) to Section 26:

A agrees to sell horse worth $1000 for RM 10 . As consent to the

agreement was freely given .

The agreement is a contract notwithstanding the inadequacy of

the consideration .

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  1. Consideration Need Not be Adequate

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ELEMENTS OF CONTRACT:

  1. Consideration

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  1. Past Consideration is a Good Consideration

General rule : English law does not recognize past consideration .

Exception to general rule :

Lampleigh v Brathwait [1615] 80 ER 255

Judgment:

An act originally done at the request of the promisor , a promise

made subsequent to the doing of that act , was deemed binding

since the act constituted consideration .

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ELEMENTS OF CONTRACT:

  1. Consideration

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Section 2(d) of CA 1950

has done or abstained from doing implies that even if the

act done before the promise, such an act can constitute

consideration as long as it was done at the desire of the

promisor .

Section 26(b)

An agreement made without valid consideration is void unless

it is a promise to compensate a person who has already

voluntarily done something for the promisor .

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  1. Past Consideration is a Good Consideration

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ELEMENTS OF CONTRACT:

  1. Consideration

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Illustration (c) to Section 26 of CA 1950

A finds Bs purse and gives it to him .

B promises to give A RM 50 . This is an agreement .

South East Asia Insurance Bhd v Nasir Ibrahim

[1992] 2 MLJ 355

Judgment:

Essence of consideration is that the promisee has taken upon itself

some kind of burden or detriment .

If the consideration and the promise are substantially one

transaction, it should not matter in what order they are given .

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  1. Past Consideration is a Good Consideration

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ELEMENTS OF CONTRACT:

  1. Consideration

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English law :

Does not recognize natural love and affection as a valid

consideration .

Malaysian Contract Act :

Recognizes natural love and affection as valid

consideration if certain conditions are complied with .

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  1. Natural Love and Affection is Valid Consideration

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ELEMENTS OF CONTRACT:

  1. Consideration

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Section 26(a) of CA 1950

Agreement without consideration, void, unless -

it is expressed in writing and registered under the law (if

any) for the time being in force for the registration of such

documents, and is made on account of natural love and

affection between parties standing in a near relation to

each other

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  1. Natural Love and Affection is Valid Consideration

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ELEMENTS OF CONTRACT:

  1. Consideration

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  1. Natural Love and Affection is Valid Consideration

An agreement made on account of natural love and

affection would be held binding in Malaysia if the

requirements of section 26 (a) are present :

it is expressed in writing

it is registered (if applicable)

the parties stand in a near relation to each other .

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ELEMENTS OF CONTRACT:

  1. Consideration

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  1. Natural Love and Affection is Valid Consideration

Illustration (b) to Section 26 of CA

A, for natural love and affection, promises to give his son, B,

RM 1, 000 .

A puts his promise to B into writing and registers it under a

law for the time being in force for the registration of such

documents .

This is a contract .

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ELEMENTS OF CONTRACT:

  1. Consideration

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English law :

General rule payment of a smaller sum is not satisfaction

of an obligation to pay a large sum .

Malaysian law :

General law in English law does not apply in Malaysia .

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  1. Accord and Satisfaction Part Payment may Discharge

an Obligation

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ELEMENTS OF CONTRACT:

  1. Consideration

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Section 64 of the CA

Promisee may dispense with or remit performance of

promise

Every promisee may dispense with or remit, wholly or in

part , the performance of the promise made to him, or

may extend the time for such performance, or may accept

instead of it any satisfaction which he thinks fit .

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  1. Accord and Satisfaction Part Payment may Discharge

an Obligation

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ELEMENTS OF CONTRACT:

  1. Consideration

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  1. Accord and Satisfaction Part Payment may Discharge

an Obligation

Illustration

A owes B RM 5, 000 .

A pays to B, and B accepts, in satisfaction of the whole debt,

RM 2, 000 paid at the time and place at which the RM 5,000

were payable .

The whole debt is discharged .

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ELEMENTS OF CONTRACT:

  1. Consideration

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  1. Accord and Satisfaction Part Payment may Discharge

an Obligation

Illustration

A owes B RM 5,000 . C pays to B RM 1,000 and B accepts

them, in satisfaction of his claim on A.

This payment is a discharge of the whole claim .

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ELEMENTS OF CONTRACT:

  1. Consideration

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  1. Accord and Satisfaction Part Payment may Discharge

an Obligation

Kerpa Singh v Bariam Singh [1966] 1 MLJ 38

Court ordered the Respondent to pay the Appellant for a sum of

RM 8,650 .

30 July 1963 Rs son offered to pay RM 4000 as payment in full

in order to discharge his father from liability .

If the Appellant did not agree to the said settlement, the money

should be returned to him .

The cheque was cashed and the money retained by the

appellants solicitor .

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ELEMENTS OF CONTRACT:

  1. Consideration

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  1. Accord and Satisfaction Part Payment may Discharge

an Obligation

Kerpa Singh v Bariam Singh [1966] 1 MLJ 38

On 6 Feb 1964 Appellant took out bankruptcy notice against the

respondent .

Court order :

Bankruptcy notice taken out by the appellant be set aside on the ground

that the appellants debt had been satisfied by smaller amount than the

original debt .

Appellant cashed the cheque given by the Rs son .

Appellant appeal on the ground : there was no accord and satisfaction .

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ELEMENTS OF CONTRACT:

  1. Consideration

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  1. Accord and Satisfaction Part Payment may Discharge

an Obligation

Kerpa Singh v Bariam Singh [1966] 1 MLJ 38

Held :

As the creditor had accepted the tender by cashing the

cheque and retaining the money, he must be taken to agreed

to discharge the debtor from any further liability .

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ELEMENTS OF CONTRACT:

  1. Consideration

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A party to an agreement can enforce the promise even if he

himself does not give any consideration as long as

somebody has done so .

Section 2(d) of CA 1950

whenthe promisee or any other person has

done something, such actis called a consideration for

the promise

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  1. Consideration Need Not Move From the Promisee

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ELEMENTS OF CONTRACT:

  1. Consideration

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  1. Consideration Need Not Move From the Promisee

Venkata Chinnaya v Verikatar MaYa [1881] 1 LR 4

Facts:

A sister agreed to pay an annuity of Rs 653 to her brothers who provided

no consideration for the promise .

But on the same day their mother had given the sister some land,

stipulating that she must pay the annuity to her brothers .

The sister subsequently failed to pay the annuity and was sued by her

brothers .

Judgment:

She was liable to pay the annuity . There was a good consideration for the

promise even though it did not move from her brothers .

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REFERENCES

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Lee Mei Pheng , Ivan Jeron Detta (2022), Business Law, 3rd Edition,

Oxford University Press.

Dr Loganathan Krishnan, Parimaladevi Rajoo , Anne Chrishanthani Vergis

(2022), Principles of Business and Corporate Law, Malaysia, 4th Edition,

CCH Malaysia.

Contracts Act 1950 (Act 136)

Federal Constitution

Civil Law Act 1965 (Act 67)

Subordinate Courts Act 1948 (Act 92), Subordinate Courts (Amendment)

Act 2010

Courts of Judicature Act 1964 (Act 91)