Cases Part 3 2023 002

Mr McDermott contended that the adjudicator had failed to exhaust his jurisdiction

by failing to consider and make a finding on the defence that the appendix had not

formed part of the IPA, with the result that there was no proper specification given

of the sums claimed in the IPA. The adjudicator had noted in the decision that Mr

McDermott had argued that AGB had not provided a basis for the calculation of the

sum claimed but had not noted the specific ground was the absence of the

appendix.

After reviewing the law as to the principles on which the court would approach an

application to enforce an award, the court noted an adjudicator could not rely on a

general assertion that s/he had considered all submissions and documents. There

must be some effort to address the lines of defence advanced and to explain the

basis upon which they were accepted or rejected, failing which the decision would

be unenforceable.

Mr McDermott contended that the only questions the adjudicator had directly

addressed were (a) whether an earlier document could be incorporated by

reference in an IPA and (b) whether the letter and appendix in question provided

sufficient detail. AGB said it was clear from the terms of the decision that the

question had been adequately addressed. They also argued that the decision

should be enforced unless there was a failure to exhaust jurisdiction in a material

respect and the court should intervene only in the plainest of cases.

The court quoted a number of paragraphs from the decision, which could only be

read as deciding that the letter and appendix had been included in the IPA (at least

in the earlier application to the quantity surveyor). Whether that could be criticised

as an ill-founded conclusion in law or fact was of no consequence. The appendix

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