Challenge to jurisdiction of adjudicator must relate to decision which it is sought to enforce

In Prater Ltd v John Sisk & Son (Holdings) Ltd [2021] EWHC 1113 (TCC) Veronique Buehrlen QC, sitting as a Deputy High Court Judge, rejected a challenge to the decision of an adjudicator on the ground that the adjudicator lacked jurisdiction because of his reliance upon an aspect of a decision reached in a previous adjudication. To the extent that there was a problem with the decision in the earlier adjudication, the proper response was to challenge that decision directly and not to rely on the indirect route of raising it as an objection to the enforcement of a decision in a subsequent adjudication. The deputy judge also rejected the submission of the defendant that the claimant had sought to refer more than one dispute to adjudication in the earlier adjudication. Finally, she held that the terms of the subcontract between the parties did not permit the claimant to refer multiple disputes to the same adjudicator in the same adjudication.