As can be seen from BP v Hunt, the practical application of the Law Reform (Frustrated Contracts) Act 1943 s 1(3) is limited by the definition of valuable benefit given by Goff J. In particular, where the value of the benefit has been reduced to nil by the frustrating event, the provider of the 'benefit' has no claim. The defendant’s benefit under s 1(3) is clearly not necessarily the value of the claimant's performance.