<center><span class="news-text_italic-underline">Judgment Date: 18 December 2025</span></center>
In <span class="news-text_italic-underline">Project One London Ltd v VMA Services Ltd [2025] EWHC 3304 (TCC)</span>, the court was asked to determine whether an adjudicator’s true value decision arising from an interim payment application should be enforced. The proceedings followed earlier enforcement action concerning a separate adjudicator’s decision relating to the same payment application.
Adrian Williamson KC, sitting as a deputy High Court judge, rejected all of the defendant’s natural justice objections and ordered enforcement of the adjudicator’s decision.
The defendant alleged multiple breaches of natural justice in an attempt to resist enforcement. First, it was argued that the adjudicator had relied on a point concerning air conditioning pipework that had not been raised by either party. The court rejected this contention, finding that the adjudicator had not embarked on a frolic of his own but had reached conclusions grounded in issues that had been fully explored during the adjudication.
Secondly, the defendant contended that the adjudicator had failed to consider evidence relating to water tank costs and testing. The court held that generally, unless deliberate, an oversight or misunderstanding of evidence will not amount to a breach of natural justice. On the facts, there was nothing to suggest the adjudicator deliberately ignored any evidence. The adjudicator’s oversight or misunderstanding of the evidence could not, therefore, constitute a breach of natural justice.
Thirdly, criticism was directed at the adjudicator’s use of percentage reductions and his characterisation of elements of the valuation as arbitrary. The court concluded that the adjudicator had simply carried out the task required of him by producing the best approximate valuation possible within the compressed timescale of adjudication. This was described as precisely what the courts expect adjudicators to do.
The court emphasised that even if any breaches of natural justice had occurred, they would not have been sufficiently material to justify refusing enforcement. The adjudicator was experienced and had operated within the wide and necessarily imprecise boundaries of a true value adjudication. The judgment characterises the challenge as a familiar attempt by a losing party to dissect the adjudicator’s reasoning in search of grounds to resist compliance.
The decision reinforces the established principle that adjudication is intended to provide interim and pragmatic solutions. While parties remain entitled to challenge the substantive correctness of an adjudicator’s valuation in subsequent proceedings, the adjudicator’s decision must be complied with in the meantime. As the court reaffirmed, adjudication remains an intentionally rough and ready process forming a provisional stage within the wider dispute resolution framework.
