Council of the City of Sydney v Woodward

Council of the City of Sydney (the Council) appealed to the New South Wales Court of Appeal against a decision of the Supreme Court of New South Wales that ordered it to pay Ms. Woodward a sum of money on a quantum meruit basis. The dispute arose from Ms. Woodward's provision of services to the Council in relation to the development of a new library at the former Sydney Town Hall. Ms. Woodward had provided extensive architectural and project management services, but no formal contract was ever executed between the parties.

The Court of Appeal was required to determine the appropriate remuneration for the services rendered by Ms. Woodward, specifically whether the Council was liable to pay her on a quantum meruit basis and, if so, what that amount should be. A further issue was the date from which interest should be calculated on any sum awarded. The Court also considered the relevance of a letter sent by Ms. Woodward to the Council, which proposed a significantly lower remuneration than what she ultimately claimed.

The Court of Appeal found that Ms. Woodward was entitled to recover on a quantum meruit basis, as she had provided valuable services at the request of the Council, and it would be unjust for the Council to retain the benefit of those services without payment. The Court reasoned that the letter proposing a lower remuneration was not determinative of the reasonable value of the services, but rather an indication of an early, tentative proposal that was superseded by the ongoing provision of extensive work. The Court applied principles of restitution to assess the reasonable value of the services, considering the scope of work, the expertise required, and the market rates for such services.

The Court of Appeal ordered that the Council pay Ms. Woodward a sum of $1,150,000, with interest to be calculated from the date of the Supreme Court's judgment.