What is the test for unjust enrichment in the context of unpaid domestic services?

There is no doubt that the provision of domestic services can support a claim for unjust enrichment. On a straightforward economic approach, there is no reason to distinguish domestic services from other contributions. They constitute an enrichment because such services are of great value to the family and to the other spouse; any other conclusion devalues contributions, mostly by women, to the family economy. The unpaid provision of services (including domestic services) or labour may also constitute a deprivation because the full-time devotion of one’s labour and earnings without compensation may readily be viewed as such. See Kerr, at para. 42. In Peter v. Beblow, 1993 CanLII 126 (SCC), [1993] 1 S.C.R. 980, at p. 993, McLachlin J. (as she then was) quoted Lord Simon’s observation that: “The cock-bird can feather his nest precisely because he is not required to spend most of his time sitting on it.”