In the case of the illness or death of one who has undertaken personally to manufacture or produce something for another, in the course of such manufacture or production and before the passing of title, the part performance, if it may be so called, is obviously of no benefit to the other party and cannot properly form the basis of a quasi contractual recovery. This was pointed out by Johnson, C.J., in Wolfe v. Howes,1 where he is reported to have observed that:

"It was material that the defendants had received actual benefit from the services of the plaintiff's testator, and that quite a different question would be presented by a case where the services actually rendered should prove valueless; as, e.g. if one should be retained to compose any original literary work, and having faithfully employed himself in preparation, should die without having completed any work of value to the employer."