Ward reaffirmed the well-established requirement that a solicitor's bill must allow the client to have sufficient information to decide whether to seek taxation, and held that the proper principle was that there must be something in the written bill to indicate the ambit of the work, but that inadequacies in the bill of description of the work done may be redressed by accompanying documents or the client's knowledge.
Ward upheld the existing rule that a solicitor's bill must give clients enough information to decide whether to seek taxation, and stated that the key principle was that the bill should clearly state the scope of work performed, but that any gaps in the description could be addressed by supporting documents or the client's own knowledge.