Historically, the courts have been less willing to grant relief to a person who rendered services to another by mistake than to a person who paid money by mistake1. One reason may be that services, unlike money, cannot be restored2. The general rule is that, where the recipient of services has neither requested them3 nor freely accepted them4, he has no liability to pay for them or for any benefit thereby conferred5 In exceptional cases, however, liability has attached, as where the services would have had to be performed by someone if not the claimant
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