What is the effect of the absence of consideration in the context of a motion to set aside a voluntary conveyance?

As well, because of the absence of consideration, it was not necessary to prove fraudulent intent on the part of the transferee in order to have a voluntary conveyance set aside under the statute. Armour J.A. in Oliver v. McLaughlin et al. (1893), 24 O.R. 41, said at p. 51: It is only where a conveyance is made upon good consideration that it is necessary under the statute in order to set it aside to shew the fraudulent intent of both parties to it. But where a conveyance is voluntary, it is only necessary to shew the fraudulent intent of the maker of it.