Fortune Favours The Brave
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Fortune Favours The Brave
We need to speak about the Defective Premises Act - Part 2
The Supreme Court’s ruling in URS Corporation Ltd (Appellant) v BDW Trading Ltd (Respondent) [2025] UKSC 21 has been highly anticipated and is now regarded as one of the most significant construction law rulings in recent years. It marks the Court's first major interpretation of both the Defective Premises Act 1972 and Building Safety Act 2022.
Morgan Taylor, Claims and Technical Executive at Howden, and Jonathan Carrington, Senior Associate at RPC, examine the background to the case, the Court’s findings, and the potential implications for construction and property professionals moving forward.
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Speaker 2:Hi, welcome to the Howden podcast, fortune Favors the Brave. This is part two of a series discussing the Defective Premises Act with Jonathan Carrington of RPC. Welcome back, jonathan. Hi, there we go. Well, we finished the last bit on a bit of a cliffhanger, as it were. We got too involved in discussing the DPA, which I don't think anybody's ever said before. But here we are. So looking at everything that's been going on recently and indeed, looking at the DPA. What else has the Supreme Court said about the DPA, jonathan?
Speaker 3:Okay, I mean in the Supreme Court, and we'll. We'll deal with more generally the other issues that the Supreme Court had to look at, but as regards the DPA, as you know, one of the things the Building Safety Act 2022 did is introduce, through Section 135, extended time limits or limitation periods for claims under the DPA Prior to the Building Safety Act. The time limit or limitation period for claims under Section 1 of the DPA remember Section 2A, the other duty which we discussed only came in with the Building Safety Act, so we're only dealing with extending time limits for Section 1. The Section 1 duty was six years from when the work was completed. So in some ways, that's probably why we haven't seen many DPA claims, because you only had six years to make them, and it's six years from the date the works were completed, or what you would call in construction, practical completion. Now, section 135 of the Building Safety Act, or the BSA as we've been calling it, has introduced a new Section 4B to the Limitation Act 1980, which extends the limitation period for claims under Section 1 of the DPA to 30 years retrospectively and 15 years prospectively, which means works completed prior to 28 June 2022, which is when the BSA came into effect will be subject to a 30-year limitation period and were completed after 28 June 2022, will be subject to a 15-year limitation period. This means that it is now possible for many occupiers and people who hold or acquire an interest in a dwelling, which otherwise would have had their claim time barred or statute barred, they can now bring a claim where defective works means their property is not fit for habitation. So all those old claims are alive again. And this is where it gets interesting and why the Supreme Court decision is very important for purposes of the DPA.
Speaker 3:The new time limit in Section 4B of the Limitation Act 1980, that Section 35 of the BSA has introduced for certain actions suggests and we all thought it only applied to extending time limits for claims under the DPA. However, if you read the section carefully, as the Supreme Court did, obviously it's worded slightly more widely, because it says where, by virtue of a relevant provision, a person becomes entitled to bring an action against any other person, no action may be brought after the expiration of 15 years from the date on which the right of action accrued. So it's the word. It's not as simple as saying because there were two claims. Or rather, put it differently, limitation periods for two types of claims was extended by Section 135. One of them was the DPA and the other one was this vague thing called building safety defects, which we still don't know what that means. We will find out in due course. Wait for the next podcast, or at least wait for the next court decision to tell us what it means, because I don't think most people know what it means. But anyway, the words used in that extension of time is by virtue of a relevant provision. It doesn't say we extend time limits or limitation periods for claims brought under the DPA. It says by virtue of a relevant provision which is wider. And those are the words the Supreme Court looked at and said.
Speaker 3:Well, let's just first go back a step and just recap what URS was saying. Who was the appellant in the Supreme Court? Urs argued that the extension of the limitation periods introduced by Section 135 of the BSA only applies to actions under Section 1 of the DPA. So it's quite a strict interpretation. And it does not apply to claims which are related or dependent on the time limit under the DPA. So it's only claims under the DPA.
Speaker 3:Now, the reason why URS said that is because in their matter, in their fight with BDW, bdw had a negligence claim against URS and a contribution claim against them. Bdw's negligence claim against URS was and still is the claim still continues basically that the developments had various serious structural defects as a result of URS's failure to exercise reasonable skill and care in the provision of its design services and that failure was a breach of URS's common law duty of care and tort. So negligence which was concurrent with and arising out of the obligations assumed by URS under its contracts with BDW. Furthermore, urs said the existence of certain of the structural defects presented a health and safety risk, basically a building safety defect, which is something which would fall normally under the DPA. So that was BDW's negligence claim. Bdw's contribution claim is basically that both BDW and URS owe the homeowners of these developments a DPA duty and they are both liable to the homeowners for the same damage, so that they may seek contributions from each other under the Civil Liability Contribution Act 1978.
Speaker 3:Now BDW's negligence claim against URS for remedial works is not obviously a claim under the DPA, but it is a claim which is dependent on or related to or indirectly based on the DPA and in particular the time limits for bringing a DPA, because their DPA claim against BDW was time barred. Then there was no legal ie DPA obligation on BDW to carry out the remedial work and BDW had voluntarily carried out these works, which was, let's say, the primary or URS's primary or first ground of appeal that they had voluntarily carried out this work. They didn't have a legal obligation to carry out these remedial works and therefore they couldn't claim the cost of the remedial works from URS in tort. They voluntarily carried out the work. So URS argued that they cannot recover the cost and the tort and negligence which BDW had voluntarily incurred and they argued that as a matter of law, that as a principle of law. They argued that there's this thing called a voluntariness principle which we'd never heard of before. But it was a clever argument that they went through all the authorities and basically said if you look at the law of negligence, if you voluntarily incur loss, that's your problem. My duty of care to you doesn't include you doing things like that. My duty of care to you is that if you have to do something because of my negligence, fine, that falls within my duty of care, but not if you voluntarily do that. So in a sense and I think this is the tricky bit and it's where people are going to do the real analysis of the Supreme Court decision. I think both BDW's negligence claim and their contribution claim were based or dependent on the DPA time limit, because if the DPA time limit wasn't extended then there was no legal obligation and that had huge complications for the negligence claim and the contribution claim.
Speaker 3:And the Supreme Court held that when the meaning of the words in section 135 are considered in the light of their context and purpose and maybe just pause there the words we mentioned earlier, which is by virtue of a relevant provision, it's not like a claim under a DPA, so it's by virtue of a relevant provision.
Speaker 3:If these words are considered in the light of their context and purpose, and when you read the Supreme Court judgment from beginning to end, you will see the context and purpose.
Speaker 3:They repeat a number of times and the context is obviously the disaster, the Grenfell Tower fire, but then the context also includes the subsequent building safety crisis and it includes the Building Safety Act and it also includes and I think this is important the government encouraging developers to to remediate buildings and entering into contracts and putting pressure on developers to sort out buildings. And that is the context against which the Supreme Court had to look at this matter. And I think that is the most important thing about the Supreme Court judgment, because it shows that the Supreme Court has supported the government's efforts to encourage developers to repair buildings, and they've done this by making it easier for them to recover their losses from others. And they've done that by not accepting arguments like URS's arguments, which would limit the scope and effect of the DPA, and by saying no, none of those arguments work. The DPA is a lot more powerful than perhaps we all thought.
Speaker 2:I think that's very fair and equally, it's so powerful that it's able to overturn something which URS suggested was a principle of law and again, as you said, not a principle that we'd necessarily heard of previously, but one which makes sense to a degree that losses voluntarily incurred shouldn't necessarily be recoverable. You can understand the thought behind that but, as you say, when considered in the wider context here, is the phrase voluntarily incurred necessarily fair? Or rather, should we be considering that BDW was in a position where there was governmental pressure to make those remediations work and consequently there's sort of a question as to the voluntariness of that? I don't know if voluntariness is a word, so it does all raise some interesting questions and it is relatively positive perhaps to see the judgment that's been rendered in that regard. But just to go from exactly what we've said and really staying on Supreme Court decisions, I think it'd be really helpful for us to look at the decision in URS and BDW handed down by the Supreme Court at the end of May.
Speaker 2:Now this is still hot off the press, we're still figuring out what's going on and equally, I think, as you mentioned prior to this recording, jonathan, it feels as though everybody in the country is writing about it at the moment. So what can you give us in terms of a summary of the judgment? And I know I'm giving you a bit of a Herculean task here. It's a fairly hefty one.
Speaker 3:Yes, no, everyone is reading it, writing about it. So by the time this podcast goes out, I'm sure people would have at least had three different views. But we've all been waiting for this decision. Construction matters hardly ever go to the Supreme Court. Well, most matters don't go to the Supreme Court in the sense most matters don't go all the way. They normally settle along the way.
Speaker 3:But everyone was really excited, if that's the right word. Well, let's put it all construction law geeks were excited by this decision because, well, one, you're getting the Supreme Court to look at construction law and tell us what the DPA means. Tell us, and it's first real opportunity for the Supreme Court to consider the Building Safety Act and all this new law, all this new legislation. But to be fair, the main reason why everyone was excited is because we thought the Supreme Court would change the law, and that was the reason why the Supreme Court convened a full panel of seven judges or lords. They need seven if there's a risk that they have to overturn the previous House of Lords or Supreme Court decision. Seven if there's a risk that they have to overturn the previous House of Lords or Supreme Court decision. So it's a big deal and we thought that meant that one of the oldest decisions, the House of Lords decision in Pirelli, was going to be looked at again and perhaps overturned. Pirelli basically decided that damage for building defects occurs when there is physical damage which caused all kinds of troubles, because later on it was decided that damage for building defects occurs when there is physical damage which caused all kinds of troubles, because later on it was decided that actually damage for building defects is pure economic damage. And pure economic damage is suffered at the latest at completion of the building works. And that's been a problem in law for a while. So we're all getting excited that urs was going and urs did sort of argue in their written case that pirelli maybe is wrong and needs to be sorted out once and for all. But in their oral argument in december 24 they didn't push the point and the court wasn't asked to go through all the you know, look at pirelli in detail and actually decide whether it's right or wrong. So that was a bit of a damn squid because the court didn't overrule Pirelli and said it didn't have to think about it. So that was disappointing to all the geeks. But perhaps by way of summary now I've said why it's so exciting and in fact what we were hoping would happen didn't happen and in fact what we were hoping would happen didn't happen.
Speaker 3:Let's just step back and just give a broad summary of the case which has been going on for years. Bdw, or BDW Trading, is a major commercial property developer and they are seeking to recover from URS, which is a major structural engineering consultant, the remedial costs they incurred as a result of serial structural defects in various developments which URS had helped design. And this is the interesting part of the case and why perhaps it's gone all the way to the Supreme Court Because by the time BDW carried out the remedial work it had no proprietary interest in the developments. No claim had been made against it by anyone, by the owners or occupiers of the developments, and there was no claim to be made against them in the sense that any claims were statute barred or time barred. So you can see why URS argued that something was wrong here, that BDW could not recover the remedial costs from them in negligence because they didn't have to pay these remedial costs. They didn't have to do the work. They had, in URS's argument, voluntarily incurred these costs. And a person's duty of care in negligence does not generally extend to protecting another from costs voluntarily incurred. Basically, that's your problem if you take on cost you didn't have to take on. And that was the first ground of appeal.
Speaker 3:And the supreme court disagreed and said there was no voluntarist principle.
Speaker 3:English law according to which repair costs are irrecoverable as a matter of law and I think that's important as a matter of law because those costs are outside the scope of duty of care or too remote that doesn't mean that the reason why BDW did the work when maybe they didn't have to do the work is not relevant. But not as a matter of law, because the court said whether it was reasonable for BDW to carry out the remedial work was still relevant to legal causation and mitigation, whether there was a break in causation or whether the real reason why they incurred losses was their own fault, basically, or whether they failed to mitigate their losses, whether they could just do nothing. But the court said those issues are not before them, those are factual issues which will still need to be decided at trial. So, as a matter of law, this whether the the fact that bdw voluntarily carried out the work is not relevant because, as I said, there's no voluntariness principle in english law, but it could still be an issue at trial yeah, of course, and separately.
Speaker 2:It's something that came up in our discussion earlier on with regards to the wider context, which was critical in this case, and indeed the question of the government's push for such works to have been done regardless and, consequently, the rationale behind everything that bdw did. So I do think it's well.
Speaker 3:I think that's a that's an important point because the general message coming from the supreme court is we will support the government's efforts to encourage developers to repair buildings. Now, if the Supreme Court held that developers cannot recover costs they have voluntarily incurred or some would say responsibly incurred, because the government or just because they felt they needed to, because there was a reputational risk If they didn't they would be in the media, et cetera. And the reputational risk was an issue which I won't get into but was one of the big issues as to whether that was the reason it wasn't voluntary, that they had this risk. But ultimately the Supreme Court also said and I think even though they said whether they carried out the works voluntarily still needs to be cited at trial they did give a very strong indication that they didn't think BDW performed the repairs voluntarily because of the risk of personal injury or death to the homeowners. So those duties to homeowners personal injury or death are still alive and well. So there still was an obligation on BDW to do the work because if they didn't, people might get hurt. Well, so there still was an obligation on BDW to do the work because if they didn't people might get hurt. Basically. So you can see how unattractive URS's argument was to the Supreme Court. They want to encourage people to do the work, basically. That's why this voluntariness principle. They didn't like it.
Speaker 3:Now, that was the first ground of appeal dealing with BDW's claim and negligence. And the second ground of appeal we've sort of already mentioned and that is to do with the interpretation of Section 135 of the Building Safety Act which, as you know, extends the time limits for claims under the DPA, and whether or not that extension of time only applies to claims under the DPA or whether it applies to claims like BDWs negligence and contribution claims, which are not claims under the DPA but they depend on the DPA time limits. And, as we discussed, the Supreme Court disagreed and held that Section 135 not only applies to claims under Section 1 of the DPA but also to other claims which are dependent on DPA limitation periods, such as BDWs negligence and contribution claims. Now you can see the danger of that and that's where all the action is going to be, because basically, what you might then be able to do is bring claims and negligence and contribution claims long gone time barred bring them because somehow they're dependent on the dpa time limit. So the the extension of time limits for the dpa could open up, could extend the time limits for all these other types of claims.
Speaker 3:Now the Supreme Court made it very clear that they were only looking at the circumstances of the BDW versus URS situation. But you can imagine what people are going to do. They're going to say my claim, my negligence claim, is dependent on the DPA time limit. Therefore, I have 15 or 30 years instead of what you say. Well, that I had six years.
Speaker 2:So that that's what's going to happen it's a it's a definite concern, I think, for people to consider now. I mean looking at the 30-year retrospective period especially, there's potentially now a risk of floodgates being opened and claims from as far back as 1994 perhaps sorry, 1995 coming to light. I forgot the date there. So it is certainly a concern and equally, I'm sure it will be a concern moving forward. So certainly more than ever, it's a good time for construction professionals to keep solid records of the work that they do in order to really ensure that, if we do see those extended time limits being utilised in order to bring further claims, that they do have at least some documentation to try and support their own case. Just trying to introduce a slightly positive element into what is a fairly significant concern.
Speaker 3:Unfortunately, at this stage, I think also, what will come up quite quickly is whether, because retrospective provisions are so rare and onerous, there is a provision in the Building Safety Act which says it's subject to, basically, convention on Human Rights, and there'll be lots of interesting arguments as to why the 30-year period is a breach of my rights. And one of the interesting arguments will be whether, for instance, if a construction professional doesn't have a single document on this project and is not able to defend themselves, whether that's worth anything, are you able to say, listen, I don't know anything about this project, I can't say anything. Whether that is an issue, a reason why the limitation period shouldn't be extended for purpose of this particular claim. But the direction of travel is clear the supreme court decision, the building safety act, basically everything that's happened since grenfell, is directed to maximum liability, to enabling people to basically make claims against those ultimately responsible all the way down the supply chain. Yeah, and I think that is the general message the Supreme Court is giving.
Speaker 2:And I think equally a lot of that ties back to part of the rationale behind rejecting the voluntariness principle in the first instance says in many, many cases, an obligation to protect against physical harm or loss of life.
Speaker 2:Here, when considering a number of the claims that could be pursued and you can see why of course it'd be a bit of a public relations nightmare if, all of a sudden, the government and the courts were quite willing to accept defences which prohibited such claims from going ahead. And it's a, it's very much being stuck between a rock and a hard place, I would imagine at this stage where, on one hand, yes, you can, you can recognize that significant claims are going to come forward in order to mitigate the risk to life on and the costs incurred in trying to mitigate those risks, whilst on the other hand, seeing claims being brought against you after just shy of 30 years is likely going to be a fairly bitter pill to swallow for a number of construction professionals who have long since forgotten those cases and indeed had no idea at the time of the potential concerns that may emerge later on down the line. So certainly a difficult scenario to be in, if nothing else.
Speaker 3:No, definitely. But I suppose the question is, if not contractors, who? Well, quite, I mean, the difficulty with arguing is to say, well, homeowners should pay. Why should they pay? Because if the homeowners, the construction profession, doesn't play, then it's the government. The government has been paid, and I think you can see that's the message as well. We're not paying anymore, we want everyone else to pay. So the other perhaps?
Speaker 3:There were two other grounds of appeal in the Supreme Court. Urs's third ground of appeal also an interesting point was that commercial developers like BDW are not owed a duty under Section 11A of the DPA because basically they're not the sort of person, a large commercial developer to whom such a duty is owed. Basically because that's not what the dpa was meant to protect. It was to protect first-time homeowners, ordinary citizens, and we've discussed that and again. The supreme court disagreed and held that bdw, a developer, was the sort of person to whom a duty under section 11a of the dpa is owed, and it also held that the relevant work was carried out by urs to the order of those are the words in the act of bdw, and urs therefore owed bdw a duty under section 11a of the dpa.
Speaker 3:Urs's fourth and final ground of appeal was that bdw was not entitled to bring a contribution claim against urRS under the Civil Liability Contribution Act 1978 because there had been no judgment or settlement between BDW and any third party and no third party had ever asserted any claim against BDW.
Speaker 3:Again, the Supreme Court disagreed and it held that BDW was entitled to bring a contribution claim against URS because BDW had paid compensation in kind by doing the remedial works for the damage suffered by the homeowners by carrying out repair. And the fact that there was no judgment against BDW or admission of liability or settlement between BDW and any of the homeowners and there wasn't even a claim against BDW was irrelevant and did not prevent BDW from claiming contribution from URS. So you can see how far the Supreme Court has gone to ensure that the DPA and the provisions of the DPA are not limited or restricted and similarly, in respect of claims of negligence are not limited and the way the DPA is used to keep all those claims alive because again, as we discussed, they're trying to encourage everyone I guess not only developers to sort out problems for homeowners.
Speaker 2:No, and it is all, I suppose, laudable in that regard, isn't it? You can see exactly where the rationale behind these decisions lay, so it's all exceptionally useful to understand and equally moving forward. It'll be interesting to see further cases come forward now URS and BDW hotly anticipated, not least due to the scarcity of such cases reaching the Supreme Court or, as you said earlier on, any cases reaching the Supreme Court in the first instance at all, and so it's really helpful for us to have a solid debrief of exactly what this judgment could mean. Moving forward Now, I'm certain that much of this will have been of some concern to a number of the construction professionals in the industry, certainly in the wake of the various articles that will have come out in the weeks since the judgment and indeed off the back of discussions like this. Now, I think it's important to consider that, whilst there are some concerns here, jonathan, will the DPA apply to all defects? Is it going to always be the case that construction professionals have to worry about the DPA being relevant in every single instance?
Speaker 3:No, I think that it is important to emphasize that it's not all defects. And what do you mean by defect? A defect is anything which doesn't comply with the contract or the specification. But here we're dealing with building safety defects, basically dangerous defects, and if not dangerous, at least defects which make it impossible for you to live in the dwelling. So the test is still quite high.
Speaker 3:The DPA test is whether the defects render a dwelling unfit for habitation, which is quite a high test, a high bar. It's a very fact-specific test. There isn't a general rule as to what constitutes a defect which renders a dwelling unfit for habitation and it is a very fact-specific question whether any particular defect or defects render a dwelling unfit or habitation. The courts have held that there doesn't need to be an imminent danger. The defect can be patent or latent, but it has to be a serious defect and basically it must be impossible to live in the dwelling or the defect must pose a risk to the occupier's health or make it impossible for them to reasonably live within the dwelling. So if the dwelling lacks something essential, like a roof with a damp course, or other examples are if the foundations are inadequate, or the obvious example is if there are fire safety defects, of course, and you must remember the IRS BDw case is not about fire safety defects, it's about structural defects. And I think that's what grenfell did as well, because after grenfell everyone went back to their buildings and looked really hard at them and if there wasn't a fire safety cladding issue behind the cladding there might have been other issues. So that's why so many more defects have come out of the woodwork.
Speaker 3:But other defects which the courts have considered render a dwelling unfit for habitation, like in the BDW, the structural although this issue hasn't been decided in BDW, you must remember in the BDW URS case they haven't had a trial yet. These are all preliminary issues, so they'll still need to decide whether the structural issues are serious enough to render the dwelling unfit for habitation. Issues like damp or black mold have been held to render dwellings unfit for habitation, dwellings infested with pests such as rats or bugs unfit for habitation, inadequate drainage, sewage or water supplies, so it's basically anything which makes it impossible to live in a dwelling. So it's not every defect. It's got to be a serious defect, if you can call it that, before the DPA applies.
Speaker 2:I think that, if nothing else, should offer some comfort. Excellent. So this is all really important information. It's all been a really helpful discussion Now. Now can contractors and construction professionals limit or even cap their potential liability under depa jonathan well, that's what we're all scratching our heads about.
Speaker 3:What do we do? Um, because, as we said, the supreme court is basically maximizing liability for serious building safety defects and our initial view is no, you can't do much about it Because, as Lord Leggett said in his concurring judgment, an important feature of the statute of duty is that it is impossible to contract out of it. So if you look at the DPA, section 6.3 of the DPA provides, at any term of an agreement which purports to exclude or restrict, or has the effect of excluding or restricting, the operation of any of the provisions of the DPA, or any liability arising by virtue of such provisions shall be void. And a good example of that was in the recent case, the Vanka case, which we've mentioned previously. The court held that a net contribution clause in an architect's appointment was a restriction on the architect's liability arising out of the DPA and it therefore fell foul of section 6.3 of the DPA and could not be relied on by the architect in respect to liability under the DPA.
Speaker 2:It'll be interesting to see how that develops further. One can imagine a defense being raised against the use of a liability cap or a net contribution clause just through virtue of it in some way impacting one's liability under the DPA, even if that's not our relevant question at the time. It'll be interesting to see if there are any fun arguments brought by much smarter legal professionals than I on such elements. And then, finally, it looks like the DPA has become a more important remedy. Are there any other developments which make you think the DPA could or will be used more often?
Speaker 3:Yes, I mean statutory duties as a whole become much more important. So we all know that parties to a construction contract have a statutory right to adjudicate and you cannot exclude that right by way of contract. So that's the power of statute. You can't agree otherwise, basically.
Speaker 3:But what is also very significant is a recent judgment BDW. Bdw is making the law at the moment versus Ardmore Construction Limited the 2024 case, where the TCC held that a DPA claim was a dispute under the contract pursuant to Section 108.1 of the Housing Grants, construction and Regeneration Act and an adjudicator could therefore have jurisdiction to determine a DPA claim. Ardmore has appealed the decision that an adjudicator has jurisdiction to decide a DPA claim and I understand the appeal will be heard on either the 22nd or 23rd of October 25. So again, the DPA will be considered by the appeal court again. But that's obviously a very important decision because if DPA claims can be brought by way of adjudication and I can't do anything to limit my liability under the DPA, we might have a floodgates type situation where we've got lots of DPA claims coming at us by way of adjudication.
Speaker 2:Absolutely Well. It is a slightly doom, demon, gloom-esque review of the situations it stands, but it is important to note, I suppose, that it's still relatively early days on a number of these matters and, equally, we don't know exactly how things are going to develop, which is especially interesting when we think back at the fact that the DPA has been around for 53 years now and we're still making and seeing very critical decisions made there, and indeed decisions that we would have otherwise considered to be relatively fundamental. So it remains to be seen how a number of these things will play out in full, and I'm sure we could revisit this episode in a year's time and have a vast array of wider discussion to be had as well. But I think that's all we have time for with regards to our discussion on the DPA today. Thank you very much, jonathan, and thank you to all of our listeners. Pleasure, thank you, thank you.
Speaker 1:Thank you for listening to this episode of Fortune Favors the Brave from Howden. To hear more episodes and subscribe to our channel, search Fortune Favors the Brave on your favorite podcast app.