Cases Part 3 2023 002

subcontractors. It was thus likely that evidence of content and value of work would

be needed.

If the condition was operable, the next question was whether the condition’s precedents were satisfied. There were multiple sub-elements. There was the

question of timing. It was in dispute whether the requirement of clause 21.4 that the

sub-subcontracts be provided within 7 days was part of the condition precedent;

that would be a matter of pleading and argument. What would happen if

compliance was one day late? Did that mean no payment was due for any work at

all?

The various elements required properly particularised claims and responses.

Then there was the question as to whether IPS had actually complied with the

conditions. Some of the material before the court suggested that professional

indemnity insurances were not required from at least two sub-subcontractors who

had no design responsibility.

The allegations made in the adjudication were not all the same as those advanced

before the court. A properly particularised claim was required.

The question of compatibility between the subcontract and sub-subcontracts

would, if pursued, require factual analysis.

The question of waiver was very likely to involve evidence of previous payments and

practice. It did not follow that previously decided cases in which it was said payment

was equivocal would apply. IPS contended those cases could be distinguished as

being based on payment notices and payment practice, whereas here IPS relied on

the fact of payment on previous occasions as unilateral waiver. Only once any

breaches had been identified would it be possible to determine whether there was

a waiver.

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