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ARTICLE · 21 NOVEMBER 2025

Legal Developments In Construction Law: November 2025

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The recent case of VMA Services Limited v Project One London Limited [2025] EWHC 1815 (TCC) reinforced the required payment of notified sums due under the Housing Grants...

United KingdomReal Estate and Construction
Brad Fearn
Brad Fearn
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1. Adjudicator's jurisdiction to order payment of an interim application notified sum within a True Value Adjudication

The recent case of VMA Services Limited v Project One London Limited [2025] EWHC 1815 (TCC) reinforced the required payment of notified sums due under the Housing Grants, Construction and Regeneration Act 1996 (the "Construction Act") notwithstanding any ongoing true value adjudication ("TVA").

VMA Services Limited ("VMA") were engaged by Project One London Limited ("POL") under a mechanical and electrical sub-contract (based on the JCT sub-contract form) for works in Chelsea. VMA submitted a Payment Application in June 2024 ("PA8") and POL issued neither a Payment Notice or Pay Less Notice. The sums in PA8 remained outstanding and POL issued a TVA for an assessment of PA8. VMA raised as a defence that the sums due under PA8 had become a notified sum under the sub-contract, and within the meaning of the Construction Act, and were therefore

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