Beagle v ACT and Southern New South Wales Rugby Union Limited

[2017] ACTCA 29

ACT Court of Appeal

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Interrogate

Catchwords

1. Restitution
2. › Quantum meruit
3. › Unjust enrichment
4. › Services rendered at request of another
5. › Whether enrichment of defendant
6. › Whether material contribution to benefit obtained
7. › Whether unjust to deny remuneration
8. › Relevance of causal connection between services and benefit
1. Restitution
2. › Quantum meruit
3. › Defences and factors negativing recovery
4. › Whether services provided as part of a business
5. › Whether non-business status precludes recovery
6. › Whether relevant to assessment of injustice
1. Appeal
2. › Appeal by way of rehearing
3. › Appellate review of factual findings
4. › Findings based on credibility of witnesses
5. › Whether findings glaringly improbable or contrary to compelling inferences
6. › Whether primary judge failed to consider strength of losing party's case
1. Appeal
2. › Appeal by way of rehearing
3. › Inferences from undisputed or established facts
4. › Appellate court in as good a position as trial judge
5. › Weight to be given to trial judge's conclusion

Quick Take

A person who identifies a potential commercial opportunity and delivers a proposal to a potential counterparty is not entitled to a quantum meruit commission merely because the opportunity later materialises, where the services did not materially contribute to the benefit obtained and the parties formed their relationship independently. The fact that a claimant was not operating as part of a business does not preclude a quantum meruit claim but is a relevant factor in assessing whether denial of remuneration is unjust.