Adjudication, natural justice and defences which might have been raised

In Clerkenwell Lifestyle (UK) Ltd v HG Construction Ltd [2026] EWHC 1406 (TCC) Jefford J held that an adjudicator had not breached the principles of natural justice in reaching his decision. In particular, she held that it is a pre-requisite to any finding that there has been a breach of the principles of natural justice as a result of a failure by an adjudicator to consider a material defence that the defence, or the matters said to constitute that defence, has been raised, either expressly or by clear inference, in the adjudication itself. In the present case the point now taken by the defendant had not been raised in the adjudication and so it could not be said that the adjudicator had breached the principles of natural justice in failing to take account of the defence.