Quantum Meruit in Singapore: Getting Paid for Work Done Without a Signed Contract

Short answer: Often, yes. If your company did work at the customer’s request and expected to be paid, a Singapore court can award a reasonable sum, called quantum meruit, even where no price was agreed or the contract never came into being. The claim fails if the work was done at your own risk or an agreed term covers payment.

Work often starts before the paperwork is finished: a fit-out begins on a verbal go-ahead, a consultant keeps advising while the engagement letter sits unsigned, or a supplier delivers extra services nobody priced. When the customer then refuses to pay, the question is whether your company can still recover anything. This guide explains quantum meruit in Singapore for business owners: the two kinds of claim, when courts refuse them, how a reasonable sum is valued, the evidence to collect, the time limit, which court hears the claim and the process from letter of demand to judgment. Whether an oral or WhatsApp deal is itself a binding contract is covered in our guide on whether a verbal agreement is binding in Singapore; money sent to the wrong account is a different claim, covered in our guide to recovering a mistaken payment.

Raffles Corporate Services works with a panel of experienced Singapore law firms who offer cost-effective and efficient legal service and advice. This article is general information only and is not legal advice.

Quantum meruit in Singapore: what is it and when can a company claim it?

It is a claim for a reasonable sum for work done or services supplied, used where there is no agreed price to sue on. The Latin phrase means “as much as he has deserved” (Eng Chiet Shoong at [37]).

Typical situations where a Singapore company considers it:

• Work started on a verbal instruction or a draft contract, and the contract was never signed or finalised.
• The parties agreed the work but never fixed a price, for example extra services added mid-project.
• Work was done in anticipation of a formal contract, such as a management or consultancy agreement, that never materialised.
• The contract that both sides relied on turns out not to be enforceable, so a lawyer looks for another basis for payment.

Quantum meruit is not a shortcut around a contract that does exist. If a signed contract fixes the price, your company sues for that price as a debt or for damages for breach. Quantum meruit fills the gap where no agreed figure exists.

What is the difference between contractual and restitutionary quantum meruit?

A contractual claim says the customer agreed, expressly or by implication, to pay a reasonable sum. A restitutionary claim says there was no contract at all, but the customer would be unjustly enriched if it kept the benefit of your work for free.

The Court of Appeal set out the framework in Eng Chiet Shoong v Cheong Soh Chin [2016] 4 SLR 728. Compensation for work done where there is no express contract may rest on contractual or restitutionary grounds (at [28]); the contractual approach comes first (at [41]). The High Court in Rabiah Bee bte Mohamed Ibrahim v Salem Ibrahim [2007] 2 SLR(R) 655 (at [123]) put the distinction this way: where a contract is silent on the amount of remuneration, or says remuneration is payable without fixing it, the claim is contractual; where the claim corrects the defendant’s otherwise unjust enrichment, it is restitutionary.

In practice a lawyer usually pleads both, with the contractual claim first and restitution in the alternative. There is no statute that creates the claim; it comes from case law, while the court process is governed by the Rules of Court 2021.

When will a Singapore court refuse a quantum meruit claim?

Mainly when the work was done at your own commercial risk, or when an agreed term already deals with payment. Courts will not rewrite a deal that the parties actually made.

• Work done at your own risk. The Court of Appeal quoted with approval the observation that work done before a contract is formed is often done at the risk of the party doing it (Eng Chiet Shoong at [27]). Pitches, free proposals and tender work usually fall here. In the same case, the claim for managing additional investment funds failed because the work was done with a wider joint venture in view, rather than for a separate fee.
• An inconsistent contract term. In Turms Advisors APAC Pte Ltd v Steppe Gold Ltd [2024] SGHC 174 (unreported), the mandate letter said fees for additional services were “to be agreed”. The High Court held there was no basis to imply a reasonable sum (at [122]) and that a restitutionary claim cannot exist in parallel with an inconsistent contractual promise (at [123]).
• No request or acceptance. Work that the customer never asked for and had no chance to refuse is hard to charge for.
• The implied contract is artificial. Courts imply a contract only where necessary and where the parties’ intentions support it (Eng Chiet Shoong at [29]).

How does the court decide what a reasonable sum is?

By evidence of what the work was worth: market rates, expert evidence, the time and resources spent and how far the work got. The court then adjusts for the facts.

Eng Chiet Shoong shows how this works. The claimants had coordinated a property project for about three and a half years in anticipation of a management contract that was never signed. An expert said a reasonable fee would be 3% to 5% of the estimated project cost of A$100 million, and that about 30% of the work had been done. The Court of Appeal put the fee at the top of the range, A$5 million, because the client’s interference made the job harder, then awarded A$2 million (40% of A$5 million) to reflect that the project was stillborn and the claimants’ own inexperience (at [87] to [92]).

For a smaller business claim, the useful evidence is usually:

• your company’s standard rate card or quotations to other customers for similar work;
• timesheets, man-days and materials actually used;
• quotations exchanged with this customer, even if never signed;
• industry rates from an independent professional if the amount justifies an expert;
• evidence of what stage the work reached and whether the customer is using it.

Expect the court to discount for defects, incomplete work or poor value. A claim pitched at the full price of a finished project, when the work stopped halfway, invites a lower award.

What evidence should your company collect?

Evidence that the customer asked for the work, knew it would be paid for, received it, and of what it was worth. Gather it as soon as payment is disputed.

The other side’s own messages admitting the work or promising payment are often the strongest evidence. Keep them in their original form.

How long do you have to bring a quantum meruit claim?

Plan on 6 years from when payment fell due, and act well before that. Contract claims are time-barred after 6 years, and although restitutionary claims sit outside the statute, delay still weakens your evidence.

Section 6(1)(a) of the Limitation Act 1959 provides that actions founded on a contract or on tort cannot be brought after 6 years from the date the cause of action accrued. A contractual quantum meruit falls within it. In Esben Finance Ltd v Wong Hou-Lianq Neil [2022] SGCA(I) 1 (unreported), the Court of Appeal held that claims in unjust enrichment are not covered by section 6, and that the doctrine of laches did not bar them either. That is not a reason to wait: a lawyer will usually plead contract first, and old claims are harder to prove. For how a signed acknowledgment or part payment restarts the contract clock, see our guide to the debt limitation period in Singapore.

Which court hears the claim, and what is the process step by step?

The amount claimed decides the forum, and every route starts with a written demand and an offer to settle. Court proceedings in the Magistrate’s Court, District Court and High Court are conducted by a Singapore Advocate and Solicitor acting for your company.

The limits above are those published by the Singapore Courts on their start a civil claim page. The usual sequence is:

1. Reconcile the account: list the work, dates, rates and any payments received, and fix a figure you can justify.
2. Send a letter of demand setting out the work, the basis of the claim and the sum, with supporting documents.
3. Make a written offer of amicable resolution, open for at least 14 days unless the parties agree otherwise (Rules of Court 2021, Order 5, Rule 2). Mediation or a reduced settlement figure are common offers.
4. If there is no settlement, your solicitor files an originating claim and statement of claim in the right court, pleading contractual quantum meruit and, in the alternative, unjust enrichment.
5. The case proceeds through case conferences, exchange of documents and, if needed, expert evidence on value, to trial or settlement.
6. If judgment is obtained and not paid, your solicitor takes enforcement steps.

For more on each court, see our guide on how to sue a company in Singapore. We do not quote solicitors’ fees; the main cost drivers are whether a contract is denied outright, the volume of documents and whether expert valuation evidence is needed. Ask for a written fee estimate before starting.

What does the company secretary prepare, and what does the solicitor do?

Your company secretary or corporate service provider (CSP) assembles records and authorisations; a Singapore Advocate and Solicitor advises on the claim, drafts and files court documents and appears in court.

Raffles Corporate Services does not give legal advice or act in court; a law firm from our panel handles any proceedings. If the customer denies ever asking for the work, speak to a lawyer before you send anything that might be read as agreeing to a lower figure. After judgment there is no ACRA lodgement for a money claim; the follow-up is in your accounts, where an unpaid sum is either collected or provided for.

What are the common mistakes in claiming payment for work without a contract?

Most come from starting work before agreeing price, then claiming more than the evidence supports.

• Starting work on a verbal “go ahead” without a written confirmation of scope and rate.
• Signing or accepting a contract clause that leaves fees “to be agreed”, which can block a reasonable-sum claim.
• Invoicing the full project price for work that stopped partway.
• Doing extensive free work during a pitch and then trying to charge for it.
• Deleting chats or failing to keep timesheets, leaving no proof of the work or its value.
• Waiting years before sending a demand, while witnesses move on.

Our free tools help with related compliance and record-keeping checks.

Frequently asked questions

Can I claim payment if the customer never signed my quotation?

Often, yes. If the customer asked for the work and accepted it, a court may find an implied contract to pay a reasonable sum, or order payment to prevent unjust enrichment. The quotation is evidence of the expected rate.

Will I get the full amount I invoiced?

Not necessarily. The court awards what the work was reasonably worth, not your invoice figure. It may discount for incomplete work, defects or your own inexperience, as the Court of Appeal did in Eng Chiet Shoong.

Can I claim for work done during a tender or pitch?

Usually not. Work before a contract is formed is often done at the risk of the party doing it. A claim is more likely where the customer asked for substantial work beyond a normal pitch and expected to pay for it.

Does quantum meruit apply if my contract says fees are “to be agreed”?

It may not. In Turms Advisors v Steppe Gold [2024] SGHC 174 (unreported), a “fees to be agreed” clause meant the High Court would neither imply a reasonable sum nor allow a parallel restitutionary claim.

Can I file a quantum meruit claim at the Small Claims Tribunals?

Possibly, if the claim arises from a contract for services or goods, is within S$20,000 (or S$30,000 with both parties’ consent) and is filed within 2 years. Take the online pre-filing assessment to check eligibility.

Last reviewed: 7 November 2026. The Editorial Team, Raffles Corporate Services.