Skymist Holdings Ltd v Grandlane Developments Ltd

Skymist Holdings Ltd v Grandlane Developments Ltd

The adjudicator had jurisdiction because Grandlane did not rely on a contract containing the disputed nominating body clause; the appointment by RICS was correct under the Scheme. There was no clear and unequivocal approbation of the DOA by Grandlane, nor any benefit gained, so the doctrine of approbation and reprobation did not apply.

Parties
Claimant: Skymist Holdings Limited; Defendant: Grandlane Developments Limited
Jurisdiction
England and Wales
Judgment Date
19 December 2018
Procedural Posture
Part 8 Claim (challenge to Adjudicator's Jurisdiction) / Judgment After Hearing
Outcome
Claim dismissed
Legal Topics
Adjudication, Jurisdiction, Approbation and Reprobation, Contract Formation, Dispute Resolution

Case Brief

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Parties

Skymist Holdings Limited

Claimant

Grandlane Developments Limited

Defendant

Procedural Posture

Part 8 Claim (challenge to Adjudicator's Jurisdiction) / Judgment After Hearing

  1. 1 Whether the adjudicator had jurisdiction given the route of appointment and the contract terms
  2. 2 Whether Grandlane was precluded from seeking appointment by RICS due to approbation and reprobation

Ratio Decidendi

The adjudicator had jurisdiction because Grandlane did not rely on a contract containing the disputed nominating body clause; the appointment by RICS was correct under the Scheme. There was no clear and unequivocal approbation of the DOA by Grandlane, nor any benefit gained, so the doctrine of approbation and reprobation did not apply.

Court Disposition

Claim dismissed

Orders

  • Skymist's claim is dismissed