What is the test for setting aside a default judgment where the court is satisfied service has not been done?

The case law is clear that if the court is satisfied service has not been effected upon a defendant, then any subsequent default judgment against that defendant is a nullity and the defendant is entitled to have the order set aside as of right. The discretionary considerations usually invoked in cases of this sort, and which have been articulated in Miracle Feeds v. D. & H Enterprises Ltd., [1979] B.C.J. No. 1965, simply do not apply to applications to set aside default judgments where proper service was not first effected.