Under wrongful withholding of services is included breach of contract: for the obligation to render services may be grounded either on contract, or upon other titles: in other words, the event of a man's engaging in a contract is one out of many other investitive events from which the right of receiving them may take its commencement.

Were the word services to be taken in its utmost latitude (negative included as well as positive) this one head would cover the whole law. To this place then are to be referred such services only, the withholding of which does not coincide with any of the other offenses, for which separate denominations have been provided.

IPML Chapter 16 Section 3 Part 1