Account was one of the oldest forms of actions ex contractu.

"For several hundred years the action of account occupied no mean place among the common-law remedies. In modern times the bill in equity for an accounting has been found to be better adapted to the enforcement of the obligation to render an account, and the old legal remedy has consequently fallen into disuse. The count in assumpsit for money had and received has also been extended into the field formerly occupied by the action of account.14