"For as much as he has earned". A right to recover on a quantum meruit may be available to the innocent party following breach of a service contract as an alternative to seeking damages. The remedy is based on an implied term to pay a reasonable sum for work done and therefore, applies for example, to a partly finished building.

Contracts falling within the purview of laws requiring contracts to be in writing are not rendered void by such laws on grounds of illegality or otherwise. They are contracts supportable by actions at law or in equity. For example, a partly completed building contract where the builder has wrongly been prevented by the other party from completing can claim and recover fair value for what he has done by an action outside the contract   Trimtor Building v Hilton (1983).