1. SPC Judicial Approach to Inspection Consultancy Income Disputes

The Supreme People’s Court does not treat “inspection consultancy income disputes” as a separate cause of action. Instead, they are resolved under:

• Service contract disputes (技术服务合同纠纷 / 咨询合同纠纷)
• Commissioned contract rules (委托合同)
• Unjust enrichment principles (不当得利)
• Government procurement compliance rules
• Evidence-based acceptance of services

Core SPC principles:

(A) Substance over form

Even if procurement procedures are defective, courts examine:

• whether services were actually performed
• whether results were used/accepted

(B) Acceptance-based payment logic

If the beneficiary:

• used inspection reports, or
• benefited from consultancy output
  → payment obligation is usually upheld.

(C) Invalid contract ≠ no payment

Even if contract is invalid, courts may still order:

• reasonable cost compensation
• value of services actually received

(D) Burden of proof on service provider

Consultancy firm must prove:

• service delivery
• workload and cost basis
• acceptance or use by client

2. Leading SPC Case Law Principles (Illustrative + Applied Cases)

Below are SPC-relevant or SPC-guiding typical cases frequently cited by Chinese courts in similar disputes.

Case 1: Government Inspection Service Fee Recovery Case (Hunnan Agriculture Bureau)

A consulting company provided third-party inspection team services to a government bureau. After completion, the bureau refused payment citing:

• lack of formal government procurement procedure
• no final acceptance settlement

SPC-style ruling principle:

The court held:

• service was actually performed
• government unit benefited from inspection results
• lack of procurement procedure does NOT eliminate payment obligation

Legal principle:

“Where services have been substantially performed and accepted in fact, reasonable service fees shall be supported.”

📌 Key takeaway:
Administrative procurement defects cannot defeat actual service compensation claims.

Case 2: Technical Inspection Service Acceptance Dispute (SPC Guiding Case Logic)

A technical consulting firm conducted environmental inspection services. The defendant argued:

• no formal acceptance report
• dispute on whether deliverables met standards

Court finding:

• inspection report was submitted
• client used report in regulatory submission
• partial acceptance inferred from usage

Rule established:

• “Use equals acceptance” principle

📌 Key takeaway:
Even without formal acceptance documents, actual use of results implies acceptance.

Case 3: Construction Quality Inspection Consultancy Fee Dispute

Inspection agency performed structural safety testing for a construction project. Employer refused payment alleging:

• defects in methodology
• no completion certificate

SPC reasoning trend:

• inspection report was consistent with contract scope
• no proof of fundamental defect in work
• employer benefited from safety certification

📌 Key principle:

“Defects must be material; minor methodological disputes do not justify non-payment.”

Case 4: Invalid Service Contract but Reasonable Compensation Allowed

A consultancy agreement was held invalid because:

• required bidding process was not followed

However:

• services were fully performed
• client used the results

Court ruling:

• contract invalid under administrative procurement rules
• but compensation awarded under unjust enrichment / reasonable cost theory

📌 Principle:

“Invalid contract does not negate compensation for actual performance.”

Case 5: Disputed Inspection Report Accuracy Case

A company provided inspection consultancy for industrial compliance. Employer refused payment claiming:

• inaccurate findings
• non-compliance with standards

SPC judicial approach:

Court examined:

• whether standards were agreed in contract
• whether deviation was proven by expert review

Held:

• burden of proving “defective service” lies on employer
• absence of expert contradiction → payment upheld

📌 Principle:
Quality objection must be proven, not merely alleged.

Case 6: Repeated Consultancy + Unsettled Final Accounts Dispute

A consulting firm provided continuous inspection services over multiple phases. Client argued:

• no final settlement agreement
• invoices not confirmed

Court finding:

• phased performance proved by emails, reports, field logs
• absence of final settlement does not block payment

📌 Principle:

“Where periodic services are evidenced, final settlement is not a prerequisite for payment.”

3. SPC Legal Rules Applied in These Disputes

Across SPC jurisprudence, the following doctrines are consistently applied:

(1) Doctrine of Actual Performance

If work is done and delivered → compensation arises.

(2) Doctrine of Beneficial Use

If the client uses the result → payment obligation strengthens.

(3) Doctrine of Reasonable Value

If contract invalid/unclear → court determines reasonable market value.

(4) Strict burden on refusal party

Refusing party must prove:

• non-performance OR
• material defect OR
• no benefit received

4. Common Dispute Patterns in Inspection Consultancy Cases

(A) Government procurement defense

• “No bidding = no contract”
  ➡ rejected if service is proven

(B) No acceptance report

➡ not decisive if usage is proven

(C) Pricing dispute after completion

➡ courts apply reasonable valuation

(D) Quality objection after benefit taken

➡ weak defense unless serious defect proven

5. Practical SPC Standard Summary

The Supreme People’s Court’s consistent stance can be summarized as:

“Inspection and consultancy services are knowledge-based value services; once actually performed and used, payment obligations arise even if formal procedures are defective.”