A wife who receives substantial financial benefit from a home loan used to purchase the matrimonial home in which she holds a beneficial interest is not a 'volunteer' for the purposes of the Yerkey v Jones principle, and that principle is not engaged in such circumstances. However, the question of whether the Yerkey v Jones principle extends beyond guarantees by wholly volunteer wives to other transactions where the wife is partially a volunteer remains open and should not be resolved on a summary judgment application. The mere fact that a wife reposes trust and confidence in her husband and signs documents at his request without inquiry does not establish actual undue influence.
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