(iv) Whether the documentary evidence discloses admissions sufficient to justify judgment under Order 27 rule 3 of the Rules of Court 2012. Findings And Analysis Whether the Respondent's Challenge to the Fees and Reliance on Taxation Raised a Bona Fide Triable Issue [20] One of the principal grounds relied upon by the Respondent was that the fees claimed by the Appellant were excessive and ought to be subjected to taxation. Reliance was placed principally on a letter dated 7 June 2022 in which the Respondent described the fees as "exorbitant" and indicated an intention to challenge the bills through taxation. [21] At first glance, such a challenge may appear capable of raising a dispute regarding quantum. However, upon careful examination of the evidence as a whole, I am unable to conclude that the allegation disclosed a bona fide triable issue. [22] The evidence shows that the Respondent had been informed of the fees claimed long before the issuance of the final invoice. Numerous pro forma invoices had been furnished over a substantial period and the final invoice issued on 30 May 2022 substantially consolidated charges which had already been communicated to the Respondent. [23] Notwithstanding the Respondent's assertion that the fees were excessive, no meaningful step was ever taken to invoke the taxation process. No taxation proceedings were commenced, no application for extension of time was filed and no explanation was provided for the prolonged inaction. [24] Equally significant is the absence of any particularised challenge to the fees themselves. The Respondent did not identify any specific item which was alleged to be excessive, unnecessary or improperly charged. No analysis of the bills was produced and no evidence was adduced to demonstrate why any particular charge was unreasonable. [25] The chronology is important. A party who genuinely disputes the reasonableness of a solicitor's fees would ordinarily be expected to take timely and concrete steps to challenge those fees through the mechanisms provided by law. Mere expressions of dissatisfaction, unsupported by any subsequent action, are of limited evidential value. [26] More importantly, the Respondent's subsequent conduct was inconsistent with the position of a party genuinely disputing the quantum claimed. The contemporaneous correspondence shows repeated requests for time to pay, proposals for staggered payments, requests for discounts and discussions concerning methods by which the outstanding sums could be settled. [27] Such conduct is difficult to reconcile with a bona fide dispute as to the reasonableness of the fees. On the contrary, it is more consistent with an acknowledgment of liability coupled with difficulties in meeting the payment obligations. [28] While the Court readily accepts that a client is entitled to challenge a solicitor's bill and, where appropriate, seek taxation, the mere existence of that right does not automatically create a triable issue. The Court must examine whether the challenge is genuine, supported by particulars and reflected in the conduct of the party advancing it. [29] Viewed cumulatively, the Respondent's failure to pursue taxation, the absence of any particularised challenge to the bills, the substantial part-payments made and the repeated attempts to negotiate payment terms substantially undermine the contention that a genuine dispute as to quantum existed. [30] I therefore find that the Respondent's reliance on taxation did not disclose a bona fide triable issue capable of defeating the Appellant's application. [31] With respect, the learned Sessions Court appears to have treated the Respondent's bare assertion that the fees were excessive as sufficient to raise a triable issue. In my judgment, that approach overlooked the absence of any particularised challenge to the fees and the Respondent's failure to pursue the taxation process upon which she sought to rely. Whether a Joint Promise Existed [32] The Respondent maintained that there was never any agreement whereby she undertook to bear the entirety of the outstanding fees. Reliance was placed on the fact that separate Warrants to Act had been executed by the Respondent, Joshua and Meneemalah respectively. [33] I accept that the original solicitor-client relationship was created through separate retainers. However, that is not determinative of the present issue. The question before the Court is not how the retainer was initially created, but whether, following the rendering of legal services and the issuance of invoices, the parties subsequently assumed a common obligation in relation to the settlement of the outstanding indebtedness. [34] In determining that question, the Court must examine the parties conduct and contemporaneous correspondence objectively and as a whole. [35] Of particular significance is the letter dated 18 February 2022 signed by both the Respondent and Joshua. The letter referred collectively to the outstanding invoices and contained assurances regarding future payment. No distinction was drawn between sums allegedly attributable to the Respondent and sums allegedly attributable to Joshua. Equally, no reservation was made that each party would be responsible only for a specified portion of the indebtedness. [36] The same theme is reflected throughout the subsequent WhatsApp communications. The Respondent repeatedly discussed payment arrangements, sought discounts, proposed staggered payments and suggested various mechanisms by which the outstanding fees could be settled. Significantly, these discussions were directed towards settlement of the outstanding indebtedness as a whole rather than any separately identified portion thereof. [37] At no material time prior to the present dispute did the Respondent assert that she was responsible only for a specific share of the fees or that the remaining sums were exclusively payable by Joshua or Meneemalah. The distinction now relied upon emerged only after the Appellant sought recovery of the outstanding balance. [38] Viewed objectively and in their entirety, the contemporaneous documents disclose more than the existence of separate retainers. They disclose a subsequent assumption of a common obligation to settle the outstanding indebtedness owed to the Appellant. [39] In those circumstances, I was satisfied that the evidence disclosed a joint promise within the meaning of section 44 of the Contracts Act 1950. [40] Section 44(1) of the Contracts Act 1950 provides: "When two or more persons make a joint promise, the promisee may, in the absence of express agreement to the contrary, compel any one or more of the joint promisors to perform the whole of the promise." [41] The statutory language is clear. In the absence of an agreement restricting recourse, the promisee may pursue any one of the joint promisors for the entirety of the obligation. [42] The statutory illustration is equally instructive: "A, B and C jointly promise to pay D RM3,000. D may compel either A or B or C to pay him RM3,000." [43] Section 45 reinforces the same principle by providing that the release of one joint promisor does not discharge the others. [44] Once such a joint promise is established, Section 44(1) confers upon the promisee a statutory right to compel any one or more of the joint promisors to perform the whole of the promise. The section does not require the promisee to first pursue all joint promisors collectively, nor does it require the promisee to determine questions of contribution before seeking recovery from any particular promisor. [45] Accordingly, the Appellant was entitled to pursue the Respondent for the entirety of the outstanding amount. [46] In my respectful view, the learned Sessions Court failed to draw a critical distinction. [47] The dispute raised by the Respondent was fundamentally a dispute concerning the allocation of liability between persons who had benefitted from the Appellant's services. [48] Such a dispute concerns contribution. It does not concern the Appellant's entitlement, as creditor, to recover the debt. [49] Section 44(2) expressly preserves rights of contribution among joint promisors. However, those rights arise as between the promisors themselves. They do not operate as a defence against the creditor's claim. [50] Even assuming that Joshua or Meneemalah ought ultimately to bear part of the liability, such a contention does not diminish the Appellant's right of recovery. [51] The Respondent's remedy, if any, lies against those parties and not against the Appellant. [52] In my respectful view, the learned Sessions Court further erred in treating the issue of apportionment as a defence to the Appellant's claim. Once a joint promise is established, questions concerning contribution arise only as between the joint promisors themselves and do not derogate from the creditor's statutory right of recovery under section 44 of the Contracts Act 1950. [53] Quite apart from Sections 44 and 45, I was also satisfied that the documentary evidence disclosed substantial admissions by the Respondent. [54] The law is settled that admissions need not be contained in pleadings alone. They may arise from correspondence, conduct and other contemporaneous documents. [55] In Vithal Kumar a/l Jayaraman v Azman Md Nor [2010] 2 MLJ 67, the Court of Appeal held that requests for additional time to pay may constitute admissions sufficient to support judgment. [56] In the present case, the Respondent did considerably more. The Respondent discussed methods of payment, proposed staggered payments, offered her property as a means of satisfying the debt and repeatedly engaged with the Appellant regarding settlement of the outstanding fees. [57] Such conduct is fundamentally inconsistent with the position of a party genuinely disputing liability. [58] When viewed as a whole, the documentary evidence demonstrates acknowledgment of indebtedness rather than a bona fide denial of liability. [59] The learned Sessions Court also appears to have understated the significance of the Respondent's subsequent conduct and correspondence. When viewed cumulatively, the substantial part-payments made, the repeated requests for time to pay, the proposed settlement arrangements and the absence of any contemporaneous distinction between individual and collective liability all point towards acknowledgment of indebtedness rather than the existence of a bona fide defence. Observations on Solicitor-Client fee litigation [60] Before concluding, I consider it appropriate to make several observations. [61] The law provides adequate mechanisms for clients to challenge legal fees which are genuinely excessive or unreasonable. [62] However, the existence of such mechanisms does not mean that every allegation of overcharging automatically creates a triable issue. A challenge must be supported by a proper factual foundation. [63] Bare assertions, unsupported by particulars or meaningful invocation of the statutory taxation process, will ordinarily be insufficient. Otherwise, any claim for professional fees could be defeated by the simple expedient of making a general allegation that the bill is excessive. [64] Such an approach would be inconsistent with both the purpose and policy underlying Order 14. Additional Observation [65] The Court further notes that during the hearing of the appeal, counsel for the Respondent indicated that the correctness of the bills was not being disputed and that the primary dispute concerned responsibility for payment. [66] Although this was not the basis upon which this Court reached its decision, the position adopted during the hearing is consistent with the Court's conclusion that the alleged dispute concerning quantum lacked sufficient substance to constitute a bona fide triable issue. Conclusion [67] For the reasons set out above, I was satisfied that the Respondent had failed to demonstrate any bona fide triable issue. [68] The legal services were rendered. The invoices were issued and received. Substantial payments were made. [69] The challenge to the reasonableness of the fees was unsupported by particulars. [70] The evidence disclosed a joint promise attracting the operation of Sections 44 and 45 of the Contracts Act 1950. [71] The dispute relied upon by the Respondent concerned contribution and apportionment rather than liability to the Appellant. [72] The documentary evidence further disclosed admissions and conduct consistent with acknowledgment of liability. Decision [73] Accordingly, I allowed the appeal, set aside the order of the learned Sessions Court and entered summary judgment in favour of the Appellant. [74] Costs of RM12,000.00 were awarded to the Appellant, subject to allocator. Dated: June 2026 (SAMRY BIN MASRI) Judicial Commisioner High Court Kuantan Counsel for the Appellant : The Law Office of Mohd Harris Peguam Bela & Peguam Cara No.20, Tkt.1, Jalan Lestari Utama Taman Amalina Lestari 27600 Raub Pahang Darul Makmur Counsel for the Respondent : Tetuan Thurairaj T. Kumar & Assc. Peguam Bela & Peguam Cara Suite 18-9, Menara 1 MK Kompleks Mont Kiara, Mont Kiara 50480 Kuala Lumpur