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ARTICLE · 07 JANUARY 2026

Freezing Orders To Enforce Adjudication Decisions

Bryan Cave Leighton Paisner
Bryan Cave Leighton Paisner
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Bryan Cave Leighton Paisner

Bryan Cave Leighton Paisner

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Insolvency is one of the risks to consider when looking to enforce an adjudicator's decision, but sometimes there is also a concern that a party might take steps to dissipate its assets to avoid payment.

United KingdomReal Estate and Construction

Summary

Insolvency is one of the risks to consider when looking to enforce an adjudicator's decision, but sometimes there is also a concern that a party might take steps to dissipate its assets to avoid payment. The way to address such a risk is to obtain what is known as a freezing order, which is an injunction stopping a party from transferring, selling or dealing with its assets, until a judgment is satisfied.

This is not a common procedure in adjudication, but a decision from December 2025, High Tech Construction Ltd v WLP Trading and Marketing Ltd[2025] 3209 (TCC) provides a useful example of how that would work in practice and the legal tests to be applied.

The adjudication

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