What is the test for enforcing an agreement where the applicant agreed to perform all his initial labour for free?

British Columbia, Canada


The following excerpt is from Franssen v. Wilkinson, 2019 BCCRT 903 (CanLII):

16. I have insufficient evidence to find the applicant had agreed to perform all the initial labour for free. Even had I found the parties originally made such an agreement, I would have found that they later changed the agreement and agreed that the applicant would be paid for his labour. The courts have said there is no need for “fresh consideration” to enforce a change in an agreement (Rosas v. Toca, 2018 BCCA 191).

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