ADJUDICATOR ENTITLED TO CORRECT OBVIOUS SLIP

Bloor Construction (UK) Ltd v Bowmer & Kirkland (London) Ltd ([2000] BLR 764)

In Bloor Construction (UK) Ltd v Bowmer & Kirkland (London) Ltd [2000] BLR 764 Judge Toulmin QC implied into a contract under which a dispute had been referred to adjudication a term to the effect that the adjudicator might correct an error arising from an accidental error or slip in his initial decision. The error must be an obvious one and it must be corrected quickly. On the facts both conditions were satisfied. While the decision seems to be a fair one on its facts, it does open up another route by which a decision of an adjudicator can be challenged. It therefore must be kept within narrow limits if it is not to undermine the purpose of the statutory scheme of adjudication introduced by the Housing Grants, Construction and Regeneration Act 1996.