Where, as here, no agreement for a fee for services rendered on request has been made, a fee may nonetheless be payable on a quantum meruit basis. The quantum meruit addresses what would otherwise be an unjust enrichment. Enrichment is unjust where there has been enrichment of one party and a corresponding detriment to the other with the absence of any juristic reason for the enrichment: Garland v. Consumers’ Gas Co., 2004 SCC 25, [2004] 1 S.C.R. 629 at para. 30.
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