Craven-Ellis v Canons Ltd    Contract – Implied contract – Quantum meruit – Work done under contract not binding upon
parties – Whether inference of fact or inference imposed by rule of law.
In 1927 the plaintiff, an estate agent, was employed by W E Ltd for a term of three years in
connection with the development of a certain estate. On 15 April 1928, a company was
formed, which purchased the estate, and the plaintiff and certain others were appointed
directors of the company. Without express agreement between the company and the plaintiff,
the plaintiff continued his work in connection with the estate and the company received and
accepted the services rendered. After acting for two months, none of the directors having
acquired the necessary qualifications as set out in the articles of the company, they all became
incapable of acting as directors.