Cases The Enforcement of Adjudicators’ Awards under the Housing Grants, Construction and Regeneration Act 1996: Part 1 of 2019 Kenneth T. Salmon and Katy Ormston
Construction & Engineering
Contents 1. Introduction
Legislation The Act means the Housing Grants, Construction and Regeneration Act 1996, as amended by the Local Democracy, Economic Development and Construction Act 2009 Pt 8. The ‘new’ provisions apply to contracts entered into on or after 1 October 2011. The main regulations are contained in the Scheme for Construction Contracts (England & Wales) Regulations 1998 (the ‘Principal Regulations’). 1 They have been amended by the Scheme for Construction Contracts (England & Wales) (Amendment) (England) Regulations 2011 2 (the ‘new Regulations’). The new Regulations apply only to contracts for construction operations in England entered into on or after 1 October 2011. For earlier contracts the Principal Regulations apply. There are separate regulations for contracts for work in Scotland applicable to contracts made on or after 1 November 2011. 3 The new Regulations apply only to contracts for work in Scotland entered into on or after this date. For earlier contracts the Scheme for Construction Contracts (Scotland) Regulations 1998 4 applies. There are new separate regulations for Wales, applicable to contracts for construction operations in Wales entered into on or after 1 October 2011. 5 A reference to “the Scheme” is to the Principal Regulations for England and Wales, or the Scheme for Scotland, as the context so requires.
2. Abuse of Process
Amey LG Ltd v Amey Birmingham Highway Ltd 3. Dispute – Whether Crystallised Barry M Cosmetics Ltd v Merit Holdings Ltd 4. Enforcement – Fraud Birmingham City Council v Amey Highways Ltd 5. Insolvency – Effect on Enforcement Michael J Lonsdale (Electrical) Ltd v Bresco Electrical Services Ltd and Primus Build Ltd v Cannon Corporate Ltd 6. Jursidiction page 4 Skymist Holdings Ltd v Grandlane Developments Ltd Natural Justice - Construction of Contract Term – Imported issue page 5 Synergy Gas Services Ltd v Northern Gas Heating Ltd 7. Parties – Correct Name page 6 Jurisdiction Fern & another v West and others (Haven Build) 8. Stay of Execution – Dissipation of Assets – Principles page 6 Gosvenor London Ltd v Aygun Aluminum UK Ltd 9. Waiver - Challenge and Reservation Had to be Appropriate and Clear page 7 Ove Arup & Partners International Ltd v Coleman Bennett International Consultancy PLC page 3 page 4 page 4
1. Introduction The Enforcement of Adjudicators’ Awards under the Housing Grants, Construction and Regeneration Act 1996: Part 1 of 2019. Kenneth T. Salmon, Consultant Solicitor and Katy Ormston, Trainee Solicitor at Slater Heelis LLP. The law is stated at 31 January 2019 and covers abuse of process, the meaning of dispute, enforcement in case of fraud, reservation in case of jurisdictional challenges, and waiver, natural justice and a Court of Appeal decision dealing with the effect of the insolvency of a party on the right to adjudicate and the enforceability of any decision. 2. Abuse of Process Amey LG Ltd v Amey Birmingham Highways Ltd 6 This was an application by the defendant to strike out the claimant’s Part 8 application to enforce several adjudicator’s decisions, as an abuse of process. The defendant (“AB”) had been retained by Birmingham City Council (“BCC”) under a PFI contract to maintain the Birmingham road network for a 25-year period. AB sub- contracted the work to the claimant (“ALG”). BCC claimed it had been overcharged by AB and obtained an adjudicator’s decision setting aside various payment certificates. BCC’s interpretation of the contract was upheld by the Court of Appeal, and they then obtained an adjudicator’s decision against AB entitling them to repayment of substantial sums and judgment enforcing the decision. AB sought to pass on its liability to ALG and issued Part 20 proceedings against them and argued that the sub-contract required ALG to adjudicate before it could litigate. AB wished to have the Part 20 proceedings heard at the same time as BCC’s proceedings against it but the Court ruled that they should be case managed separately since the sub-contract was not precisely back-to-back with the PFI contract. ALG now commenced two adjudications against AB pursuant to the sub-contract seeking payment. The adjudicator decided that ALG was not entitled to any payment whereupon ALG commenced Part 8 proceedings seeking declarations that the adjudicator had correctly decided an issue of interpretation of the sub-contract relating to the service of notices by email. In the meantime the parties agreed a stay of the Part 20 proceedings. ALG did not serve the Part 8 proceedings but instead applied without notice for directions on the basis that the proceedings were adjudication enforcement. The issue that arose was whether the Part 8 proceedings constituted adjudication enforcement subject to the consensual approach explained in the case Hutton 7 or whether they were an abuse of process since the Part 20 proceedings were already on foot.
The Court held that, where it applied, the guidance in Hutton required a consensual approach to adjudication enforcement and Part 8 proceedings that was mandatory and not optional. It would be contrary to that guidance to commence Part 8 proceedings without notice and to seek to abridge time. Although ALG’s Part 8 claim concerned adjudication, it was not within the adjudication enforcement regime requiring abridged directions. ALG’s claim could be struck out under CPR r.3.4(2) (b) as an abuse of the Court’s process or one likely to obstruct the just disposal of the proceedings, albeit the striking out of a valid claim would be the last option. Thus if the abuse could be addressed in a less draconian way, that was the correct course. The Senior Courts Act 1981 s.49(2) required the multiplicity of proceedings to be avoided. In the case of a long-term project (such as this one), more than one set of proceedings was to be expected, but the parties were not free to ignore s.49(2) and to embark on overlapping proceedings to suit their own advantage. As the Part 20 claim appeared to have become redundant, the right course was to stay those proceedings pending further order. It would be disproportionate to strike out the part 8 claim when ALG had filed evidence explaining why it had taken the course which it had. Therefore the Court would give directions for the case management of the Part 8 claim. 7 3. Dispute – Whether Crystallised Barry M Cosmetics Ltd v Merit Holdings Ltd 8 The claimant sought enforcement of an adjudicator’s award in respect of claims for variations, extensions of time and loss and expense carried out for the claimant by the defendant builder. The defendant raised two challenges. First, it claimed that there was no dispute, as the entitlement to payment had not arisen before the claimant gave its notice of intention to adjudicate. The Court rejected the argument. There was nothing in the Scheme to suggest that a dispute could only be referred after the right to payment had arisen. There was clear dispute as to the correct value of the defendant’s final account. Second the defendant said there had been a breach of the rules of natural justice in its having been prevented from fully responding to the claimant’s last submission. The adjudicator had given the defendant permission to serve a rejoinder limited in length and scope to a particular issue, though, in fact, the defendant did not so limit its rejoinder. The Court held that there was no right to respond to the very lengthy submission made by the other party, and that it was perfectly proper to impose the limitations. In deciding there had been no unfairness, the Court commented that what is “fair” is not fixed and is to be judged in the context of the particular adjudication, whilst also noting that any breach must have a significant effect on the outcome.
4. Enforcement – Fraud Birmingham City Council v Amey Highways Ltd 9
In Primus v Cannon , the Court held that the mere fact that a company was in a Company Voluntary Arrangement (CVA) did not mean that summary judgment should be refused or a stay granted. Each case depended on its own facts. Here the purpose of the CVA was to enable the company to trade out of its difficulties and recovering the monies owned to it were a key part of that objective. It was also held that a “general reservation” to challenge jurisdiction would only be effective if it was made “appropriately and clearly” and that the proper course was to make a specific challenge on every ground which was or should have been apparent. Where there was a mix of specific and general reservations, the express inclusion of the former might undermine or negative the latter. 6. Jurisdiction Skymist Holdings Ltd v Grandlane Developments Ltd 13 This was a Part 8 challenge to an adjudicator’s decision. Although the claim was issued before the decision was made, Fraser J refused to allow it to be heard in advance of the decision. Skymist engaged Grandlane to provide development and project management services. It was common ground the contract between the parties was a construction contract to which Part 1 of the Scheme applied. The challenge arose out of the appointment of the adjudicator, Mr Riches. Skymist had terminated the contract with Grandlane alleging it was owed substantial sums. Grandlane sent a first notice of adjudication and then requested CIArb 14 to nominate an adjudicator because it said the contract contained a clause providing for nomination by that body. They were relying on a document described as draft deed of appointment (referred to in the proceedings as the ‘DOA’). Skymist denied that the version of the DOA relied on was the contract and said that it did not on any view contain the adjudicator nominating clause relied by Grandlane. CIArb nominated a lawyer, Mr Silver as adjudicator. In light of Skymist’s challenge to Mr Silver’s jurisdiction, Grandlane withdrew its first notice of adjudication. Grandlane then served a second adjudication notice. Much but not all of it was identical to the first notice. It wrote to RICS Dispute Resolution Services to appoint an adjudicator under the Scheme and RICS appointed Mr Riches. It took that course on the basis that no adjudicator nominating body (ANB) was named in the contract so Grandlane could select any ANB. Grandlane’s solicitors Stephenson Harwood (SH) asked RISC to consider nominating Mr Silver or if not him some other senior construction lawyer. It did not then challenge the right of RICS to make a nomination. Thereafter Skymist by its response to referral took a jurisdiction issue: that since Grandlane’s case remained based on the DOA, the nominating body was CIArb and the request to RICS was to the wrong ANB. This was of course precisely what Skymist had objected to in the first adjudication. Mr Riches decided he had jurisdiction and would proceed.
The claimant (“BM”) sought enforcement of an adjudicator’s decision in its favour for £866,238 plus interest. The defendant (“Greyline”) opposed the application arguing that the adjudicator had failed to consider an allegation of fraud it had made in the adjudication proceedings. The adjudication concerned a final account dispute that arose out of a labour only sub-contract by which Greyline engaged BM to carry out kitchen and bathroom repairs on a council estate in London. Greyline’s case was that it had employed BM at the joint request of the local authority’s clerk of works and the main contractor site manager (one “C”), C being the sole director and major shareholder of BM. Not only did C have a conflict of interest but he colluded with the clerk of works resulting in the overvaluation of BM’s work. Greyline said the adjudicator had failed to consider its case that the payment applications underlying BM’s account were fraudulently produced, or if had considered that case, he had not given adequate reasons for rejecting it. The Court might refuse to enforce an award on the grounds of a breach of natural justice. In addition, fraud could be raised to resist enforcement unless that allegation was raised in the adjudication and considered by the adjudicator. 10 There had to have been a deliberate failure to consider a material issue. Here, the adjudicator had considered the issues of fraud when dealing with an objection to his jurisdiction and before he went on to consider the merits. He concluded the documents used in the valuation process had been genuinely prepared. There was insufficient evidence from Greyline to show a fraud had occurred, or that the effect of any such fraud was material as to the outcome, there being no evidence that the fraud had affected the valuations. The adjudicator had considered the defence and given adequate reasons for his decision. Application granted. 5. Insolvency – Effect on Enforcement Michael J Lonsdale (Electrical) Ltd v Bresco Electrical Services Ltd and Primus Build Ltd v Cannon Corporate Ltd 11 In these two conjoined appeals the Court of Appeal upheld both of the first instance rulings. 12 In Lonsdale v Bresco, the Court held that the adjudicator did have jurisdiction to hear the dispute despite the fact that the referring party was a company in insolvent liquidation. However, to allow the adjudication to continue was neither just nor convenient. It would have been an exercise in futility, as the adjudicator was only asked to deal with one claim out of several and that would have prevented the taking of an account as required by the Insolvency Rules 2016. An injunction had been properly granted.
Before the Court Skymist contended that Mr Riches was nominated by the wrong ANB and had no jurisdiction. He was nominated by the wrong ANB because: 1. By his decision Mr Riches had found the relevant contract was the DOA or at least a contract that included a clause naming the CIArb as the ANB; 2. Even if that was not so, Grandlane had “approbated and reprobated” the DOA in relying on it or version of it, whilst not following the ANB clause. Thus the decision was a nullity for want of jurisdiction. The following relevant facts were found by the Court. There was a contract between the parties. A document called the Development Management Agreement–Beaurepaire General Terms and Conditions (TC) evidenced the key terms, services and remuneration. The DOA was a 50-page document heavily revised and redrafted with a final iteration dated 9 December 2016. It was never signed and there was no evidence its term were ever agreed by both parties. Clause 7.10 contained a contractual rate of interest. Clause 12 permitted Skymist to terminate and clause 13 provided for summary termination. Clause 14 provided for adjudication in accordance with the Scheme and that the ANB was the CIArb. The termination letter sent by Skymist alleged the contract included the TC, and it was entitled to terminate for alleged repudiatory breach by Grandlane, alternatively it was entitled to terminate at will. Grandlane denied its breach, alleged Skymist was in repudiatory breach but did not claim damages as a result. Grandlane claimed £620,000 being 5% of the construction costs less payment on account (claim 1). This element of the claim was agreed. 0.5% for procuring permits, giving them £62,000 as found by the adjudicator (claim 2). Payment of monies paid to third parties. The adjudicator found Grandlane was entitled to such payments whether it had paid the third parties or not (claim 3). The Court reviewed the notice of adjudication (NOA) and concluded it was not clear which contract was being relied on by Grandlane. Objectively viewed, the NOA did not mean Grandlane was relying on the DOA. It did not rely on the adjudication provision but the Scheme. Its claim for interest was not made under the contractual provision of the DOA. Indeed in their letter of application to the RICS Grandlane’s lawyers said they now accepted there was no contract specifying CIArb as the ANB.
On analysis the Referral did not show that Grandlane had adopted the terms of the DOA in their entirety but were in fact relying on the few terms, actually relevant to the dispute, and not including in particular the terms as to interest or adjudication. It alleged a contract based on some of the terms of the DOA and other terms, none of which in the end were disputed as applying or were necessary to the resolution of the dispute. The adjudicator found that Grandlane was relying on the DOA and Skymist was not, but qualified this by noting there was common ground over some of the terms and that it was common ground that the Scheme applied. By the time the adjudicator came to make his decision claim 1 was not agreed; the only issue on claim 2 was whether the percentage of 0.5 was applied to the value of property or the construction cost. 7. Natural Justice – Construction of Contract Term – Imported Issue Synergy Gas Services Ltd v Northern Gas Heating Ltd 15 The claimant applied for summary judgment in respect of an adjudicator’s decision in its favour. The parties had entered into a sub-contract, clause 14.4 of which provided that if the defendant decided that any works done by the claimant were defective, it had to notify the claimant of the defects and specify details. If the claimant failed to make good the defects, the defendant could rectify them itself and recover the costs from the claimant. A dispute arose over the defendant’s alleged failure to pay invoices, and the claimant referred the dispute to adjudication. The defendant’s response alleged a breach of clause 14.4, namely the claimant’s failure to rectify defects, and claimed a set-off. The claimant denied that allegation and submitted Scott schedules responding to each alleged defect and noting that it had not been given the opportunity to make them good. The adjudicator considered that the interpretation of clause 14.4 was an issue, and found that the notification of defects was a precondition to setting off. As the defendant had not notified the claimant of the alleged defects, it could not claim a set-off. The adjudicator ordered the defendant to pay the claimant over £74,000. The defendant sent a cheque for around £45,700, so the claimant brought the instant application to enforce the decision in respect of the balance. The defendant submitted that the decision breached natural justice as the claimant had not argued that clause 14.4 was a precondition to set-off, and the adjudicator had not raised it with the parties, so the defendant had not been given the opportunity to address it.
The Court held that in cases of natural justice, the Courts rarely interfered with adjudicator’s decisions, unless it was plain that the adjudicator had decided a different question to that referred to him/her, or had gone about the task in an obviously unfair manner. If the final permutation as found by the adjudicator was covered by the presented arguments, it would be rare for a natural justice breach to be found. 16 The adjudicator was plainly of the view that he had to interpret clause 14.4. The question was not raised expressly on the written submissions, and the claimant simply denied the allegation it was in breach of clause 14. On the other hand, the Scott schedules were full of references to the defendant’s failure to give the claimant any opportunity to inspect or rectify alleged defects. That imported an allegation that it had been a requirement that the claimant be given that opportunity. Therefore, the adjudicator’s decision was covered by the arguments raised, and there was no obvious unfairness and no breach of natural justice. 8. Parties – Correct Name – Jurisdiction Fern & another v West and others (Haven Build) 17 Mr and Mrs Fern engaged a builder trading as Haven Build to carry out construction works to a house they intended to live in as their family home. The contract was in the standard form of the Federation of Master Builders named Haven Build as the builder and contained an adjudication clause. There was a dispute about the quality and completeness of the work and Mr and Mrs Fern referred the dispute to adjudication. The adjudicator found for them and awarded them a sum of money. Haven Build refused to pay and Mr and Mrs Fern took enforcement proceedings. The adjudication notice and the submissions of both parties named Haven Build as the respondent. In the enforcement proceedings in the High Court, the defendants were named as Keith West, Adam West and Linda West trading as Haven Build. Ms West took no part in the proceedings, but Keith and Adam West took part and denied liability. They argued that the adjudication was defective because Haven Build was named as the responding party, instead of the individuals. It was contended that Haven Build had no separate legal personality and this meant the adjudicator lacked jurisdiction. Fraser J giving judgment for Mr & Mrs Fern, rejected the defendants’ argument. For it to succeed would have meant overturning or distinguishing a number of previous authorities. In addition s.108 of the Act would then be arguably deficient as only a contracting party could be named in adjudication documents. In contrast, in Court proceedings, paragraph 5A.3 of Practice Direction (PD) 7A) required the parties using a trade name to be named individually. The defendants’ arguments were described as “wholly unmeritorious”, “bad points” and “wrong in law”. The judge referred to a case in which Akenhead J had used similar terms in similar circumstances. 18 The judge condemned the defendants for “scrabbling around for some reason to try and avoid enforcement”.
The judge also noted that no such issue had been raised before the adjudicator, nor had the defendants reserved their position. Their defence had no “prospect of life whatsoever”. 9. Stay of Execution – Dissipation of Assets – Principles Gosvenor London Ltd v Aygun Aluminium UK Ltd 19 The appellant Gosvenor carried out cladding works for the respondent Aygun. Following project delays a dispute arose over the payments claimed by Gosvenor which Aygun contended were exaggerated. In adjudication, Gosvenor was awarded some £553,000. When Gosvenor sought to enforce the award, Aygun raised allegations of fraud, and said the Gosvenor had stolen site records and intimidated witnesses and would try anything to avoid repayment of the adjudication sum. Based on discrepancies in Gosvenor’s accounts, Aygun said there was a real risk of dissipation of assets. At first instance Mr Justice Fraser gave judgment for Gosvenor on their application for summary judgment on the basis that the allegations of fraud could have been raised in the adjudication, but imposed a stay of execution . The stay was based on a disparity in the value of works in payment invoices, Gosvenor’s lack of financial viability and the likelihood of dissipation of assets if the sum was paid. The Court of Appeal held the judge had applied the correct principles to an application to stay execution of a judgment. It there was a risk of dissipation a stay might be granted regardless of the fact that judgment was based on an adjudicator’s award as an assessment of the risk of dissipation could not be carried out before the award. The Court was entitled to have regard to all relevant evidence irrespective of whether it was or raised in the adjudication or not. If however the adjudicator had heard and rejected any such evidence, the Court should have regard to that in the exercise of its discretion, as a material but not decisive factor. The same applied to evidence that might have been but was not raised in the adjudication. The consideration of such issues called for a nuanced approach when considering an application for a stay. The judge had been right to conclude that a stay could be imposed when the evidence showed there was a real risk of dissipation. Where there was an overlap between the evidence that was or might have been deployed in the adjudication and that used in the stay, the judge should determine the consequences of that overlap in deciding what evidence was to be taken into account.
The Court had to exercise its discretion in accordance with CPR r.83.7(4). It was proper to draw an analogy between a stay based on dissipation and a freezing order as the judge had done. The judge was entitled to draw adverse inferences from the lack of any explanation in response to material from which a risk of dissipation could be inferred. That was not reversing the burden of proof. The judge had adequate material before him, namely the risk represented by the company accounts, allegations of fraudulent invoicing, untrue explanation given for belated changes resulting in radically altered figures in the accounts and an inflated figure due to creditors equating to the adjudication sum. The accepted evidence cleared the necessary hurdle such that the exercise of discretion could not be said to be unreasonable. Appeal dismissed. Comment The Court of Appeal reconsidered and extended the circumstances in which the high Court can upon enforcement and stay consider or reconsider evidence used or which could have been used in the adjudication. That included in this case, but was not limited to, allegations of fraud. 10. Waiver – Challenge and Reservation Had to Be Appropriate and Clear Ove Arup & Partners International Ltd v Coleman Bennett International Consultancy PLC 21 The claimant consultancy applied to enforce an adjudicator’s decision ordering the defendant to pay the balance of professional fees due under a professional services contract. The claimant was engaged to assist in feasibility study for a high- speed transport system to link Manchester and Leeds. There was an initial agreement made in April 2016 as varied by further agreement in October 2016. The initial agreement entailed a fee of £350,000 plus VAT or reduced fee for a 20% stake in any potential joint venture if the project went ahead. The proposal was accepted and work commenced. The defendant made an initial payment of £75,000 in May 2016. By October it was apparent that the claimant would not be taking a stake in any potential joint venture and following discussions, the defendant wrote acknowledging a debt of £350,000. The claimant submitted invoices but no further payment was made. By its adjudication notice, the claimant claimed for professional engineering services pursuant to the April agreement, as varied by the October agreement and contended that the Scheme applied. The defendant took part maintaining the view, by a letter from its barrister to the adjudicator and in its response, that the adjudicator lacked jurisdiction. The letter contained what was described as a general reservation on jurisdiction, including any jurisdictional issues it had not yet had the opportunity to investigate. It raised two specific jurisdictional challenges: (a) that the claim referred was brought under more than one contract and (b) that it was brought against the wrong party.
The adjudicator found for the claimant and awarded it the balance of the fees of £275,000 plus VAT with interest, statutory compensation and ordered the defendant to pay his fees. In Court, the defendant resisted the application on several jurisdictional grounds, including, principally, that the contract was not a “construction contract” for the purposes of Part II of the Act and thus there was no right of adjudication. O’Farrell J decided that the defendant was precluded from relying on the principal jurisdictional challenge. Although the barrister’s letter and the response had raised a challenge to the Act’s applicability, neither gave details of the basis on which that assertion was made. Any challenge as to jurisdiction had to be appropriate and clear and the adjudicator had found that that issue had not been developed in detail. 22 A mere general submission was not sufficient for an adjudicator to deal with the nature of the objection. The two specific jurisdictional points which were raised had been dealt with by the adjudicator. It would not be appropriate to allow the defendant to raise a new jurisdictional challenge now. Furthermore, the general reservation of jurisdiction in the letter was too vague to be effective. It failed to articulate the specific ground for the jurisdictional objection which should have been known to the defendant at the time and purported to keep all lines of jurisdictional challenge open. But in any event, the defendant lost its right to challenge jurisdiction because it had admitted in its response that the contract was a construction contract. On that issue, even if the defendant had been able challenge jurisdiction, the scope of work under the contract was within the ambit of Part II of the Act. It related to “construction operations” which, as defined by section 105(1) (b) included future construction operations. The design and engineering work was in connection with such operations.
References: 1. Scheme for Construction Contracts (England & Wales) Regulations 1998 (SI 1998/649). 2. Scheme for Construction Contracts (England & Wales) (Amendment) (England) Regulations 2011 (SI 2011/2333). 3. Scheme for Construction Contracts (Scotland) Amendment Regulations 2011 (SI 2011/371). 4. Scheme for Construction Contracts (Scotland) Regulations 1998 (SI 1998/687) (S.34). 5. Scheme for Construction Contracts (England and Wales) Regulations 1998 (Amendment) (Wales) Regulations 2011 (SI 2011/1715) (W.194). 6.  EWHC 234 (TCC) 7. Hutton Construction Ltd v Wilson Properties (London) Ltd  EWHC 517 (TCC),  1 All E.R. (Comm) 524,  3 WLUK 419 8.  EWHC 136 (TCC) HHJ Bird, 29 January, 2019 9.  unrep. Alexander Nissen QC., judgment 5 December, 2018 10. SG South Ltd v King’s Head Cirencester LLP  EWHC 2645 (TCC), and following Speymill Contracts Ltd v Baskind  EWCA Civ 120 and Gosvenor London Ltd v Aygun Aluminium (reported below) 11.  EWCA Civ 27 (24 January, 2019) 12. A fuller report and commentary is on the Slater Heelis construction website 13.  EWHC 3504 (TCC) 14. Chartered Institute of Arbitrators 15.  EWHC 3060 (TCC) Jonathan Acton Davies QC 16. CG Group Ltd v Breyer Group Plc  EWHC 2722 (TCC). 17.  EWHC 141 (TCC) Fraser J., 21 January 2019 18. Durham County Council v Jeremy Kendall (t/a HLB Architects)  EWHC 780 (TCC) 19.  EWCA (Civ) 2695 3 December, 2018 20.  EWHC 227 (TCC) Waksman J., 19 December, 2018 21.  1 WLUK (TCC) O’Farrell J., 29 January 2019 22. Bresco Electrical Services Ltd (In Liquidation) v Michael J Lonsdale (Electrical) Ltd  EWCA Civ 27 followed
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