What is the test for establishing an easement under the doctrine of lost modern grant?

The Ontario Court of Appeal in Henderson v. Volk, 1982 CarswellOnt 1343 stated at paragraph 14: It should be emphasized that the nature of the enjoyment necessary to establish an easement under the doctrine of lost modern grant is exactly the same as that required to establish an easement by prescription under the Limitations Act. Thus, the claimant must demonstrate a use and enjoyment of the right of way under a claim of right which was continuous, uninterrupted, open and peaceful for a period of 20 years. However, in the case of the doctrine of lost modern grant, it does not have to be the 20 year period immediately preceding the bringing of an action.