Cases Part 3 2023 002

The adjudicator found that clause 21.4 of the subcontract did require production of

certified copies of the sub-subcontracts entered into by IPS, with evidence of the sub- subcontractors’ insurances as pre-conditions of payment, within a stipulated time of 7 days. She ‘confirmed’ t hat IPS had installed a compliant installation that was in accordance with the subcontract and that milestones 1-17 should be certified as accepted . She ‘advised’ (as per the relief claimed) that (i) there was no proof that IPS had been negligent in supplying incorrect and unsuitable fittings and (ii)

she was unable to determine whether or not there had been compliance with all

pre-requisites. She valued the works in the sum of £838,400 and found that Sleaford

should make payment to IPS in the sum of £323,502 and directed payment to be

made accordingly.

Sleaford declined to pay and issued Part 8 proceedings in London for declarations

as to the meaning of clause 21.4 and that, in consequence, no further payment was

due, and the award should not be enforced. IPS issued Part 7 proceedings to enforce

the award in Manchester.

IPS’s position was that the adjudicator's decision in its favour should be enforced pursuant to its Part 7 claim unless Sleaford succeeded at the concurrent hearing on

the substance of its Part 8 declarations. As to that, it said Sleaford could not succeed

at the concurrent hearing as its claims were unsuitable for summary determination

by Part 8 because the complaints of non-compliance with clause 21.4 had not been

properly particularised, and its defence to any breach depended on the resolution

of factual issues, including waiver. Sleaford accepted that the decision was valid

and unless it succeeded on its Part 8 claim, it was enforceable. It said its Part 8 claim

involved a short point of construction, and there was no need for evidence as it was ‘ incontrovertible that the sub-subcontracts had not been provided to it within 7 days and no evidence of insurance provided. Payment of (3) previous milestones could

not amount to waiver. It also pointed out that the fact that the milestones were for

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