Clerkenwell Lifestyle (UK) Limited v HG Construction Limited [2026] EWHC 1406 (TCC)

Clerkenwell sought to enforce an adjudicator's decision on extensions of time and the associated sums. HG brought a Part 8 claim seeking declarations that the decision was made in excess of jurisdiction and in breach of natural justice, and that an earlier email exchange had created a binding agreement on revised completion dates.

On natural justice, the judge held that both parties had asked the adjudicator to decide the extensions of time over the whole period of the works, which is what he did, so there was no unfairness. On the settlement, neither party had in fact conducted itself as though a binding agreement on revised completion dates existed rather than an extension of time granted under the contract, so there was no such agreement and no declaration would be made.

With both defences failing, summary judgment was granted and HG was ordered to pay 955,943.43 pounds plus the adjudicator's fees. The case shows that a natural-justice challenge fails where the adjudicator decided exactly the question the parties put to him, and that a binding-settlement argument must be borne out by how the parties actually behaved.

Mrs Justice Jefford held at paragraph 80: "There was no breach of natural justice and no reason not to enforce the Adjudicator's Decision on that ground".