What is the test for consideration of past consideration in a claim for damages?

It is also important to remember that past consideration is no consideration at all. Rather, there must be some mutuality between the actions of one party and the subsequent promise from the other party who benefits from those actions. For instance, if the detriment suffered by one party was not suffered in return for anything, or the promise of anything, from the other party, then there is no consideration. While there may well have been some hope on the part of the acting party, even the expectation of something, if there was no promise at the time of the act being performed, then there is no consideration: see MacKenzie v. MacKenzie, [1996] P.E.I.J. No. 20, (P.E.I.S.C.) at paras. 9 and 10.