Negotiable Instruments - Law of Contract
However past services may constitute valuable consideration to a bill of exchange under by s.27 of the Bills of Exchange Act that provides such valuable consideration for a bill may be constituted through "an antecedent debt or liability".
Whether the brothers-in-law in Re McArdle, above had given Mrs. McArdle a bill to exchange or promissory note of by £488 payable after their mother's death then they would have been liable on it even nevertheless the work on the house had been completed about the time of drawing the bill or promissory note.