In Pruitt v. Workmen's Comp. App. Bd. (1968) 261 Cal.App.2d 546, the petitioner was a jail inmate of the County of Nevada and he was "loaned out" to Nevada City to work on its sewage treatment plant. ( Id., at p. 547-548.) In Nevada County prisoners could volunteer for work, but did not have to do so. Those who volunteered were eligible to have five days deducted off their sentence for every thirty days work. Inmates received no compensation other than the reduction in their sentence and a carton of cigarettes once a week. ( Id., at p. 548.) The Pruitt court initially reviewed a number of cases, including an early Supreme Court decision, California Highway Com. v. Indus. Acc. Com. (1926) 200 Cal. 44, which distinguished between voluntary and compulsory work performed as an incident to penal servitude (261 Cal.App.2d at pp. 549-551). The court then examined Penal Code section 4017 and Government Code section 25359, which provide that county prisoners may be required to work, and concluded that compulsory work as an incident of incarceration was the backbone of those laws. ( Id., at p. 551.) The court ruled that the petitioner was a volunteer notwithstanding that the monetary consideration passing to the petitioner was nil and the consideration in the form of a carton of cigarettes was of mere nominal value. ( Id., at pp. 552-553.) It was noted the payment of wages was not a sine qua non of employment under workmen's compensation law. ( Id., at p. 553.) The court concluded the principal consideration passing to the petitioner was his credit on sentence time plus the release from jail confinement while he was working. ( Pruitt v. Workmen's Comp. App. Bd., supra, at p. 553.) Finally, the court cited the mandate of liberal interpretation in favor of the workman to be given workmen's compensation provisions as a material factor in their decision. (Ibid.)