Case Note: Past Consideration or Unconnected Consideration?: Rainforest Trading Ltd v State Bank of India Singapore

Yihan GOH, Singapore Management University
Man YIP, Singapore Management University

Abstract

It is trite law that a valid and enforceable contract must be supported by consideration. The recent Court of Appeal case of Rainforest Trading Ltd v State Bank of India Singapore [2012] 2 SLR 713 is a further addition to the local jurisprudence on consideration, specifically the issue of past consideration. This note considers the specific issue of past consideration and argues that its label should be discarded in favour of a more realistic one that correctly emphasises its underlying concerns.