The antipathy expressed in the law of restitution toward in-termeddlers who confer unsolicited benefits on others is addressed almost equally to altruists and self-seekers. The antipathy is expressed in various ways, by calling them "volunteers" or "officious intermeddlers" or by asserting in ringing language a proposition that is made to seem vital to a free society. This defensive proposition is often stated with more than the needed vigor, perhaps in an effort to neutralize the beguiling effect of the unjust enrichment principle. The result of the decisions seems to be that sole owners who develop or improve their own land can claim no subsidy from neighbors to whom a gain inevitably accrued. Except where lawyers were the claimants, none of the restitution claims against strangers for gains through performance of contract has aimed at more than the making up of deficits in the returns that had been promised in exchange.