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Legal Issues in Construction Conference 2015 This interactive presentation provides you with information on the RICS Legal Issues in Construction Conference plus further resources including case law.

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Legal Issues in

Construction Conference

2015This interactive presentation provides you

with information on the RICS Legal Issues

in Construction Conference plus further

resources including case law.

RICS Legal Issuesin ConstructionConference13 October 2015, London

RICS Legal Issues inConstructionConference 2015

An essential legal update for the constructionindustry

13 October 201509.30-17.30

Ambassadors Bloomsbury Hotel, 12 UpperWoburn place, London, WC1H 0HX

#RICSConstruction6 hours CPD

In association with:

RICS Legal Issues in Construction Conference offers a

timely and essential legal update for practitioners in the

construction sector. Covering case law, best practice

and procedure, this year’s programme will again

combine the expertise of the RICS with that of industry

leaders Pinsent Masons and Keating Chambers.

Designed after an extensive period of consultation with

key stakeholders, previous speakers, past delegates

and experts in the field, this conference has been

tailored by and for RICS members. Attendees will

share a wealth of business critical content, delivered

by a selection of the most respected construction law

specialists in the UK.

This unique opportunity to hear key insights on

avoiding common legal pitfalls should not be missed.

Highlights include:

• Hear an update from the Hon. Mr. Justice

Edwards-Stuart, judge in charge of the

Technology and Construction Court on recent

developments in case law

• Benefit from the combined experience of some of

the UK’s leading legal experts on construction law

• Assess the differences between common law and

civil law systems and better equip yourself to

explore business opportunities outside of the UK.

Key sessions

Liquidated Damages – a review of recent case law

Liquidated damages play an important role in

construction contracts, giving both parties certainty as

to their risks for certain defined events. This session

will review the series of recent cases which has

examined the legal basis for liquidated damages,

including the test as to when liquidated damages are a

penalty, based on the Court of Appeal decision in El

Makdessi v Cavendish Square Holdings, the effect of

contract amendments on liquidated damages and the

use of liquidated damages for changes of key

personnel.

Standard form contracts

This session will review some of the recent case law

which considered standard form contracts such as

JCT and NEC. It will cover the decisions on the NEC

form which deal with order of priorities clauses and

time bar provisions and decisions on the JCT for

which determine the basis for an appropriate

deduction for post completion defects and the final

account process.

Adjudication update

This session will review some of the recent decisions

on adjudication, including the decision in Aspect v

Higgins, the first Supreme Court decision on

adjudication which determined the timing for seeking

recovery in court following an unsatisfactory

adjudicator's decision.

Contractor insolvency

Insolvency is still a key risk in construction and this

session will provide guidance on how to manage

insolvency risks, discussing the use of performance

bonds and parent company guarantees and the issues

that may arise in that respect.

Collaborative contracting

The UK government has made it clear over the last

few years that it regards collaborative contracts as the

route for more efficient and cost effective contracting.

This session will set out the legal basis for such

contracts, discussing alliancing arrangements, how

they are meant to operate the issues that arise in

practice, as well as the use of Integrated project

insurance to deal with project risks.

Construction Act:: Payment notices

The payment mechanism and the certificates required

under the Construction Act have been around for

close to 20 years, yet new issues keep coming up.

This session will look at some recent decisions,

including ISG v Seevic and Galliford Try v Estura, and

identify the practical implications they have and the

issues that need to be considered when administering

payment provisions.

International construction projects

As RICS members are increasingly looking for

opportunities abroad, it is important to recognise that

other legal systems will operate on a different basis.

Even where an international contract such as FIDIC

issued, there are some fundamental differences

between the common law and civil law systems. This

session will compare the common law to the civil law

highlighting the key differences that affect contractual

mechanisms.

Prices

RICS/PLA member rate - £220 + VAT

Non-member rate - £297 + VAT

Groups of 3 or more booking at the same time from

the same company receive a 10% discount. 5 or more

receive a 15% discount. 7 or more receive a 20%

discount. This cannot be used in conjunction with any

other offer from RICS Conferences.

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Book your place online today - rics.org/legalissuesTel: +44 (0)20 7695 1600

"The hugely successful RICS annualconference “Legal Issues inConstruction” will take place on 13thOctober in London. As chairman, Iinvite you to come and enjoy (andlearn) from the excellent team ofsolicitors, barristers and surveyors.They have up to date guidance, hints,& tips."

Tony Bingham, Conference Chair and Arbitrator,

Adjudicator, Mediator and Barrister, 3 Paper Buildings

This year'sprogrammeView the full programme for this year'sconference

RICS Legal Issues inConstructionConference 2015

0900 - 1730

13 October 2015, Ambassador’s Bloomsbury,London WC1H 0HX

0900 Registration and r0900 Registration and refrefreshmentseshments

0930 Chair’0930 Chair’s opening rs opening remarksemarks

Tony Bingham, Arbitrator, Adjudicator, Mediator and

Barrister, 3 Paper Buildings

0945 Opening keynote – construction case law update0945 Opening keynote – construction case law update

frfrom the Tom the Technology and Construction Courtechnology and Construction Court

The Hon. Mr Justice Edwards-Stuart, Judge in

Charge, The Technology and Construction Court

1025 Liquidated damages – a r1025 Liquidated damages – a review of review of recent caseecent case

lawlaw

Simon Hargreaves QC, Keating Chambers

Liquidated damages play an important role in

construction contracts, giving both parties certainty as

to their risks for certain defined events. This session

will review the series of recent cases which has

examined the legal basis for liquidated damages,

including the test as to when liquidated damages are a

penalty, based on the Court of Appeal decision in El

Makdessi v Cavendish Square Holdings, the effect of

contract amendments on liquidated damages and the

use of liquidated damages for changes of key

personnel.

1110 Networking r1110 Networking refrefreshmentseshments

1140 Standar1140 Standard form contractsd form contracts

Shy Jackson, Partner, Pinsent Masons LLP

This session will review some of the recent case law

which considered standard form contracts such as

JCT and NEC. It will cover the decisions on the NEC

form which deal with order of priorities clauses and

time bar provisions and decisions on the JCT for

which determine the basis for an appropriate

deduction for post completion defects and the final

account process.

1215 Adjudication update1215 Adjudication update

James Thompson, Keating Chambers

This session will review some of the recent decisions

on adjudication, including the decision in Aspect v

Higgins, the first Supreme Court decision on

adjudication which determined the timing for seeking

recovery in court following an unsatisfactory

adjudicator's decision.

1300 Networking lunch1300 Networking lunch

1400 Contractor insolvency1400 Contractor insolvency

Simon Hughes QC, Keating Chambers

Insolvency is still a key risk in construction and this

session will provide guidance on how to manage

insolvency risks, discussing the use of performance

bonds and parent company guarantees and the issues

that may arise in that respect.

1445 Collaborative contracting1445 Collaborative contracting

Richard Dartnell, Senior Associate, Construction and

Engineering Team, Pinsent Masons LLP

The UK government has made it clear over the last

few years that it regards collaborative contracts as the

route for more efficient and cost effective contracting.

This session will set out the legal basis for such

contracts, discussing alliancing arrangements, how

they are meant to operate the issues that arise in

practice, as well as the use of Integrated project

insurance to deal with project risks.

1530 Networking r1530 Networking refrefreshmentseshments

1600 Construction Act – payment notices1600 Construction Act – payment notices

Justin Mort QC, Keating Chambers

The payment mechanism and the certificates required

under the Construction Act have been around for

close to 20 years, yet new issues keep coming up.

This session will look at some recent decisions,

including ISG v Seevic and Galliford Try v Estura, and

identify the practical implications they have and the

issues that need to be considered when administering

payment provisions.

1645 Inter1645 International construction prnational construction projectsojects

Mark Roe, Partner and Head of International

Arbitration, Pinsent Masons LLP

As RICS members are increasingly looking for

opportunities abroad, it is important to recognise that

other legal systems will operate on a different basis.

Even where an international contract such as FIDIC

issued, there are some fundamental differences

between the common law and civil law systems. This

session will compare the common law to the civil law

highlighting the key differences that affect contractual

mechanisms such as notices and liquidated damages.

1720 Chairman’1720 Chairman’s closing rs closing remarksemarks

1730 Close of confer1730 Close of conferenceence

Book your place online today -rics.org/legalissues

In associationwithPinsent MasonsKeating Chambers

Pinsent Masons, KeatingChambers

Pinsent Masons has been a preeminent construction

and engineering practice for over 50 years, active in

Europe, the Middle East, Africa and the Far East.

Today Pinsent Masons has 20 offices across Europe,

Asia, the Gulf and Australia as well as various regional

offices within the UK. It is ranked tier 1 in global legal

directories for construction, as well as having been

awarded “Global Construction Law Firm of the Year”

for the last eight years by Who’s Who Legal. Pinsent

Masons have over 400 lawyers dedicated to advising

on construction projects across the project lifecycle.

They advise on building and infrastructure projects in

the UK and internationally, including housing, rail,

road, health care and airport projects.

Please call us on: +44 (0)7418 7000, or email us at:Please call us on: +44 (0)7418 7000, or email us at:

www.pinsentmason.com

Keating Chambers is renowned as one of the leading

barristers’ chambers, with a thriving domestic and

international practice. The barristers at Keating

Chambers specialise in high profile construction,

engineering, energy, infrastructure, international

arbitration, procurement, professional negligence,

shipbuilding & marine engineering and technology.

Currently having 63 barristers strong, including 27

Queen’s Counsel, 30 Juniors and six door tenants/

practising associate members and international

members, the barristers are active in the UK courts

and tribunals including the Technology and

Construction Court, the Court of Appeal, the Supreme

Court and the Privy Council. Their expertise in

alternative dispute resolution covers UK and

international arbitration, adjudication (statutory and

contractual), mediation, dispute review boards and

expert determination.

Keating Chambers’ expertise extends across the

globe. Our barristers have advised and acted in a wide

variety of projects in most countries around the world.

In some cases, members of Chambers have been

admitted to the Bar, in an overseas jurisdiction, in

order to appear in front of the Court there. This

experience brings with it a familiarity of both

procedural and substantive law in numerous

jurisdictions, together with a keen ability to work

closely with lawyers and clients with diverse

backgrounds

Please call us on: +44 (0)20 75442600, or email us at:Please call us on: +44 (0)20 75442600, or email us at:

www.keatingchambers.co.uk

SpeakersImmerse yourself in this year's speakerbiographies

This year's speakers

Once again we selected the very best expertsfrom across the industry for this years LegalIssues in Construction Conference

For the full list of speakers visit rics.org/legalissues

The Hon. Mr Justice Edwards-Stuart, Judge inCharge, The Technology and Construction Court

Sir Antony Edwards-Stuart started practice at the Bar

in 1978 after completion of pupillage, following ten

years as a regular Army officer in the 1st Royal Tank

Regiment.

His practice was based mainly on insurance and

reinsurance, professional negligence, construction and

other technical disputes. He was appointed QC and

Assistant Recorder in 1991.

He was subsequently appointed a Deputy High Court

Judge (QBD & TCC), and was elected Head of

Chambers in 2005. He was appointed a High Court

Judge in 2009. He has been Judge in Charge of the

Technology and Construction Court since September

2013.

Tony Bingham, Arbitrator, Adjudicator, Mediatorand Barrister, 3 Paper Buildings

Tony Bingham is a barrister at the Construction Bar in

Chambers at 3 Paper Buildings, Temple, London. He

has been there 24 years. His career has always been

construction. He is a Fellow of the Chartered Institute

of Building; MRICS; FCInstCES, FCIArb.

Nowadays he spends most of his time deciding

construction disputes. It is a privilege to do so; it gives

insight into our industry.

So too does his Visiting Professorships at University of

Ulster and University of Northumbria. And just for fun

he has written a weekly column in Building for 28

years. That too is a privilege.

Mark Roe, Partner and Head of InternationalArbitration, Pinsent Masons LLP

Mark is a partner and Head of international arbitration,

specializing in construction and engineering matters.

Mark is recognized in the leading independent legal

research guides and by his contemporaries as a

leading lawyer for international construction.

He has had prime responsibility for the conduct of over

40 major disputes many involving US$ 100M +

claims relating to the construction, engineering and

energy industries in the last 30 years, acting nearly

always for main contractors. Mark has particular

experience of dispute resolution in the Middle East,

Asia and Africa. In addition to London he has

conducted international Arbitrations with Seats in

Paris, Geneva, Vienna, Stockholm, Amsterdam and

Amman with a variety of Substantive Laws. He

regularly appears as counsel. He has also conducted

a number of international construction disputes in the

London TCC. Mark also lectures on International

Construction Contracts, in particular FIDIC and

International Arbitration with particular regard to best

practice in the Construction Sector.

Shy Jackson, Partner – Construction Advisory andDisputes, Pinsent Masons LLP

Shy is a Partner in the Construction Advisory and

Disputes Group. He has previously worked in

Singapore and in Israel, where he qualified as a

member of the Israel Bar in 1997. Shy's practice

covers project advice and dispute resolution and he

has advised on UK and international building and

infrastructure projects. Shy is ranked in Chambers &

Partners for his construction expertise, referred to as

"a clear thinker and communicator, and technically

very good." He has experience of litigation, arbitration,

mediation and other forms of ADR.

Shy is a Fellow of the Chartered Institute of Arbitrators,

a Fellow of the Institution of Civil Engineering

Surveyors and an elected member of the Society of

Construction Law Council. He speaks regularly at

industry events, delivers training for the RICS and

lectures on the Construction Law MSc course at

King's College, London. Shy also regularly publishes

construction law related articles in various legal and

industry journals, including the RICS Journal, the JCT

Newsletter and the NEC Newsletter.

Richard Dartnell, Senior Associate – Constructionand Engineering Team, Pinsent Masons LLP

Richard is a Senior Associate in the Construction &

Engineering division of Pinsent Masons' Projects

group. He specialises in providing a wide range of

procurement and risk management advice to

employers and contractors at the outset and

throughout the lifetime of projects.

Richard has a wealth of knowledge and experience

gained on a range of contract documents including

standard form contracts (e.g. JCT, NEC, PPC2000

and FIDIC) and schedules of amendments, bespoke

construction contracts, collateral warranties,

consultants' appointments and security documents

(performance bonds and parent company guarantees).

Richard has also gained a wide amount of alliancing

experience, particularly in the Rail sector.

Richard is also a regularly speaker for the RICS,

including recently speaking on Tendering Strategies

and Appropriate Contract Selection.

Simon Hargreaves QC, Keating Chambers

Simon Hargreaves QC was called to the Bar in 1991,

served on the Attorney-General’s Panel of Treasury

Counsel from 2002 to 2008 and took Silk in 2009. He

has spent his entire career in Keating Chambers

specialising in disputes arising from construction,

engineering, IT systems, transport, energy contracts

and fires. He specialises in all forums including

litigation, arbitration, adjudication and ADR as well as

relief concerning pre-action disclosure, summary

judgment, interim payment, strike out, security for

costs, arbitration applications, injunctions and bond

applications.

Simon has been involved in a number of high profile

cases across the different areas of his practice,

principally construction, engineering, fires and IT. In

recent years he has been involved in claims arising

from: Crossrail; several PFI contracts; desalination

plant in Qatar; ferry terminal in Jordan; gold mining in

Burkina Faso; flooding in the Greenwich Millennium

Village; the Magna Park fire; the London Underground

transmission and radio upgrade project; a claim

concerning turbine design for a nuclear power station;

the Chancery Lane Tube derailment in January 2003;

the Gerrard’s Cross tunnel collapse; the London

Transport Upgrade (including Oystercard); claims

arising on Wembley Stadium; bond and defects claims

concerning the design and manufacture of a new

commuter train; tunnelling disputes; North Sea and

nuclear decontamination.

Simon has considerable experience of professional

negligence claims and related insurance claims arising

from construction, engineering, transport, IT systems,

energy contracts and fires, including claims for and

against civil and structural engineers, geotechnical

engineers, mechanical and electrical engineers,

architects, asbestos professionals and contractors,

project managers, quantity surveyors, IT consultants

and costs consultants.

Simon Hughes QC, Keating Chambers

Simon Hughes QC specialises in major construction,

engineering, shipbuilding and other off-shore and

energy related disputes and is a leading senior counsel

in these areas. Simon has been involved in disputes

involving most standard form contracts used for

substantial projects including the JCT standard forms,

ICE 5th and 6th editions, the NEC, IChemE, FIDIC

(Green, Red, Yellow and Silver Books), and derivative

standard form agreements. He has particular

experience of FIDIC forms and the NEC. In terms of

types of dispute, Simon has particular experience of

international power-plant disputes, major infrastructure

projects and shipbuilding work, particularly in the Far

East, and in disputes where the governing law is not

English law. He has represented and advised clients

on disputes in Hong Kong, Singapore, Korea,

Australia, Dubai and other parts of the UAE, various

islands within the Caribbean and New Zealand. He is a

member of the Bar in Trinidad & Tobago and was

called to the Bar in New Zealand for a specific trial on

behalf of Rolls-Royce. He has appeared numerous

times in the Court of Appeal in England, and in

Trinidad, and was recently successful on behalf of a

client in the Privy Council. He is well-known as a Court

advocate, as well as being a popular choice for

arbitration and adjudication work.

Having been involved in a number of leading cases

throughout its development, Simon has a lot of

experience of UK adjudication. He is responsible for

the chapter on Adjudication in Keating on

Construction Contracts and has lectured on UK

adjudication in the UK, Hong Kong, Singapore and

New Zealand. Simon also has a substantial interest in

FIDIC and is the author (with Jeremy Glover) of

Understanding the FODIC Red Book (now in 2nd ed.).

Simon was formerly an editor on Chitty on Contracts.

Justin Mort, QC

Justin Mort QC specialises in disputes arising out of

construction, energy, infrastructure and process

engineering projects.

He has recently worked on claims arising from a

variety of energy projects including the construction of

a wind farm in Scotland (delay claim), Pembroke

power station (termination and final account dispute), a

gas power station in Singapore, a hydro-electric dam

in Malaysia (unforeseen grounds conditions claim) and

various waste to energy plants in the UK.

Justin also specialises in injunctive proceedings. He

has recently acted for a party seeking an injunction to

prevent a firm of solicitors from acting against their

client, a mandatory injunction for return of takeover

packages removed to Italy (Alstom v SOMI), an anti-

suit injunction in the Commercial Court (U&M v KCM)

and an injunction in the Companies’ Court to prevent

the presentation of a winding-up petition. He edited

the section on injunctions in Keating on Construction

Contracts.

Justin is a renowned authority on the Housing Grants

Construction and Regeneration Act 1996. In 2013 he

expanded the application of the Act by arguing that a

collateral warranty was a “construction contract”

(Parkwood v Laing O’Rourke). In September 2014 he

successfully argued that an express contractual right

to adjudicate did not fall within the operation of the

Contracts (Rights of Third Parties) Act 1999 (Hurley

Palmer Flatt Ltd v Barclays Bank plc).

Justin Mort has an MSc from King’s College London in

Construction Law and Arbitration and occasionally

lectures at King’s. He has written articles and given

seminars on subjects relevant to his practice, including

partnering agreements and adjudication enforcement.

He has acted as an adjudicator and is on the TECBAR

panel of adjudicators.

James Thompson, QC

James Thompson was called to the Bar in 2005 and is

a specialist in the areas of construction and

engineering, energy, technology, infrastructure and

related commercial disputes. Over recent years he has

been instructed in a number of large-scale

proceedings, both as a junior and on his own, and is

recommended in the directories as “a busy junior

working on some major domestic and international

construction disputes”.

He is regularly instructed in cases involving complex

factual, legal and expert issues in the High Court, as

well as in international arbitration. He is also has

extensive experience of acting in adjudication

proceedings, both during the adjudication process

itself and at subsequent enforcement hearings. James

is often instructed to represent clients at mediation,

and has had considerable success in negotiating

settlements through this process.

James is a particularly popular choice for instructions

in the Middle East and is a committee member of the

Omani British Lawyers Association.

His recent instructions include: acting for the main

contractor in ICC arbitration arising out of the

construction of a power plant in the Caribbean; acting

as sole counsel in TCC proceedings relating to the

failure of electrical components at commercial

premises; acting as junior counsel on behalf of the

contractor in high-profile proceedings in the TCC

concerning the construction of a busway; acting as

junior counsel in proceedings before the Dubai World

Tribunal concerning a construction dispute on the

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Palm Jumeirah.

Further speakers include:

• Opening keynote: The Hon. Mr Justice Edwards-

Stuart, Judge in Charge, The Technology and

Construction Court

"We are delighted to note that thisyear’s keynote address will bedelivered by Judge in Charge of theTechnology and Construction Court,Hon. Mr Justice Edwards-Stuart.Construction and contractualdemands run hand in hand...let’s keepup to date. See you there"

Tony Bingham, Conference Chair and Arbitrator,

Adjudicator, Mediator and Barrister, 3 Paper Buildings

Stay connectedTwitter, LinkedIn and the RICS LegalIssues in Construction Conference

Networking beyond RICSLegal issues Conference

Follow and take part in discussions before,during and after this year's conference.

Twitter & LinkedInCatch up with industry news and reports via the RICSRICS

LinkedIn GrLinkedIn Groupoup

And take part in discussions before, during and after

this year's conference by using our twitter hashtag

#RICSConstruction#RICSConstruction

Further resources from

RICSView isurv case law example

RICS resources

Case law plays an important part in most surveying

specialisations.

With commentary by expert authors, isurv has over

4,000 cases reviewed by experts. This channel

provides a case overview, the outcome and advice on

the actions you can take to ensure compliance.

Case law covered includes:

• Commercial case law

• Construction case law

• Expert witness case law

• Dilapidations case law

• Party wall case law.

isurv Case Law example

AMEC Capital PrAMEC Capital Projects Ltd v Whitefriars City Estatesojects Ltd v Whitefriars City Estates

LtdLtd

(2004) 96 Con LR 142 and [2005] BLR 1 CA(2004) 96 Con LR 142 and [2005] BLR 1 CA

Construction contracts - adjudication - appointment ofConstruction contracts - adjudication - appointment of

adjudicator - bias - natural justice - radjudicator - bias - natural justice - re-determination -e-determination -

JCT standarJCT standard form with contractor's design - whetherd form with contractor's design - whether

corrcorrect to seek appointment of alterect to seek appointment of alternative adjudicatornative adjudicator

- housing grants, Construction and Regeneration Act- housing grants, Construction and Regeneration Act

1996 - Scheme for Construction Contracts (England1996 - Scheme for Construction Contracts (England

and Wand Wales) Regulations 1998, clause 2ales) Regulations 1998, clause 2

The responding party challenged the decision of the

adjudicator on the basis of apparent bias. The test

applied by the Court of Appeal was whether a fair-

minded and informed observer, having considered all

the circumstances that have a bearing on the

suggestion that the decision-maker was biased, would

conclude that there was a real possibility that he was

biased: Porter v Magill at paragraph 103.

The adjudicator in this case was initially appointed and

made his decision in favour of the referring party.

However, that decision was found to be unenforceable

because the adjudicator had not been properly

appointed.

The same adjudicator was subsequently reappointed

in a second adjudication concerning the same

matters.

The judge at first instance held that there was a real

possibility of bias in the present case by reason of the

combined effect of the facts that:

(a) on AMEC's case, the issues were the same in the

two adjudications;

(b) on the basis of the adjudicator's findings, the

issues that he had to decide were the same in both

adjudications;

(c) the legal advice obtained in the first adjudication

may have been 'carried forward' into the second

adjudication and influenced the second decision;

(d) the adjudicator did not give the parties an

opportunity to comment on the legal advice obtained

on the jurisdiction issue in the second adjudication;

and

(e) the adjudicator had a private conversation with the

solicitor representing the referring party, which was

limited to an explanation of why he was being re-

appointed.

The Court of Appeal overturned the decision of the

first instance judge on the following grounds:

(a), (b) The mere fact that the tribunal has previously

decided the issue is not of itself sufficient to justify a

conclusion of apparent bias. Something more is

required. The vice that the law must guard against is

that the tribunal may approach the rehearing with a

closed mind.

(c) This was a new point that had not previously been

raised and which was too late to raise now.

(d) Natural justice requires no more than that a party

should have an effective opportunity to make

representations before a decision is made. In the

court's view, Whitefriars had such an opportunity in

the present case and took advantage of it. In any

event, the common law right to prior notice and an

effective opportunity to make representations is to

protect parties from the risk of decisions being

reached unfairly. But it is only directed at decisions

that can affect parties' rights. In this case the legal

advice related to the adjudicator's own jurisdiction,

which was not binding on the parties.

(e) Conversations between one party and the tribunal

in the absence of the other party should be avoided.

Communications should ordinarily be in writing with

copies to all parties. But the Court of Appeal saw

nothing in the circumstances of this conversation,

which arose out of an innocuous telephone call to the

adjudicator's office, which would lead the fair-minded

and informed observer to conclude that what was said

would give rise to a real possibility of bias

For more information on what isurv covers contact

TEL: +44(0)24 7686 8433.

For a free isurv trail visit www.rics.org/isurvhub