1. Concept and Meaning

A quantum meruit claim arises where:

• One party has provided goods or services to another, and
• It would be unjust for the recipient to retain the benefit without paying for it.

It is grounded in the broader legal idea of Unjust Enrichment, meaning no person should unfairly benefit at another’s expense.

2. Legal Basis (Indian Context)

Quantum meruit is not explicitly named in statutes but is recognized under the Indian Contract Act, 1872, particularly through:

• Section 65 – Obligation of person who has received advantage under void agreement
• Section 70 – Obligation of person enjoying benefit of non-gratuitous act

3. When Can a Quantum Meruit Claim Arise?

(i) Void Agreements

When an agreement is discovered to be void, but one party has already performed part of it.

(ii) Non-Gratuitous Acts

If a person lawfully does something for another without intending it to be free.

(iii) Partial Performance

Where a contract is partly performed and then discharged.

(iv) Breach of Contract

When one party prevents the other from completing performance.

(v) Indivisible vs Divisible Contracts

Quantum meruit applies more easily to divisible contracts than indivisible ones.

4. Essential Conditions

To succeed in a quantum meruit claim:

1. Services must be rendered lawfully
2. The act must not be gratuitous
3. The other party must enjoy the benefit
4. There must be no valid enforceable contract governing the payment (or it has become void/discharged)

5. Important Case Laws

1. Craven-Ellis v. Canons Ltd.

• A director worked under an invalid appointment.
• Court held he could recover remuneration for services rendered.
  Principle: Payment allowed when work is done under a void contract.

2. Planche v. Colburn

• Author was hired to write a book but publisher cancelled midway.
• He was allowed payment for the work already completed.
  Principle: Quantum meruit applies when one party prevents completion.

3. Sumpter v. Hedges

• Contractor abandoned work midway.
• Court denied full recovery but allowed payment for materials accepted.
  Principle: Partial recovery depends on acceptance of benefit.

4. Cutter v. Powell

• Sailor died before completing contract.
• No payment granted as contract required complete performance.
  Principle: No quantum meruit if contract is indivisible and incomplete.

5. State of West Bengal v. B.K. Mondal & Sons

• Contractor built structures without formal contract.
• Government used them.
• Court allowed compensation under Section 70.
  Principle: Compensation for non-gratuitous acts benefiting another.

6. Puran Lal Shah v. State of Uttar Pradesh

• Work done under a void contract.
• Compensation granted for benefit received.
  Principle: Quantum meruit applies to void agreements.

7. M.P. Housing Board v. Progressive Writers & Publishers

• Payment allowed for partially completed work when employer benefited.
  Principle: Fair compensation for benefit retained.

6. Situations Where It Does NOT Apply

• When services are rendered gratuitously
• When a valid contract already specifies payment terms
• When the claimant is guilty of breach without benefit to the other party
• When the contract is indivisible and incomplete (as in Cutter v. Powell)

7. Difference from Damages

• Quantum meruit: Payment for value of work done
• Damages: Compensation for loss suffered

8. Practical Example

If a contractor builds half a house and the owner stops the work but uses the construction, the contractor can claim reasonable payment under quantum meruit.

9. Conclusion

Quantum meruit ensures fairness where strict contractual rules would otherwise lead to unjust outcomes. It prevents one party from benefiting unfairly and promotes equity in contractual and quasi-contractual relationships.