Can a defendant force a plaintiff to disgorge the benefit received in exchange for improvements to a farm?

The court ultimately concluded the improvements to the farm fell outside the law of unjust enrichment. To hold otherwise would be to allow a plaintiff the privilege of unilaterally determining another’s obligation: The law of unjust enrichment thus construes the absence of donative intent not unilaterally, as a subjective matter taking place in the plaintiff's head, but rather bilaterally, as an inter-subjective matter taking place between plaintiff and defendant. Forcing the defendant to disgorge the benefit received in the absence of this bilaterality would amount to granting the plaintiff the privilege of unilaterally constituting another's obligation. Unrequested benefits fall outside the law of unjust enrichment in that, having failed to display the required bilaterality, their disgorgement would itself be unjust. [Original emphasis] (See also Simonin v. Simonin, 2010 ONCA 900, at ¶23, 24.)