This document discusses two types of quantum meruit - contractual quantum meruit and restitutionary quantum meruit. Contractual quantum meruit refers to an implied contractual right to payment for services rendered when no payment terms are specified. Restitutionary quantum meruit is based on concepts of unjust enrichment and applies when services are provided without an express or implied contractual right to payment. The document explores the differences between the two types of quantum meruit and addresses criticisms of awarding restitutionary quantum meruit in certain cases. It also discusses how the distinction applies to alternative dispute resolution service providers like arbitrators and adjudicators.