A LITTLE OF TIME AT LARGE:

PROOF OF A REASONABLE TIME TO

COMPLETE IN THE ABSENCE OF A
COMPLETION DATE

A paper given to the

Society of Construction Law
in London on 4th October 2005

Keith Pickavance and

Wendy MacLaughlin

October 2005

www.scl.org.uk
 A LITTLE OF TIME AT LARGE:
PROOF OF A REASONABLE TIME TO
COMPLETE IN THE ABSENCE OF A
COMPLETION DATE

Keith Pickavance and

Wendy MacLaughlin

Introduction
Rarely does one come across a contractor’s claim without finding in it
somewhere the allegation that the employer is not entitled to any liquidated
damages and ‘time is at large’. Provided that there is a contract completion
date, a power under the contract to extend time, and the contract administrator
(CA) properly exercises that power, a new date for completion can be
enforced. This is usually calculated by adding to the initial date for
completion the additional time required for the effect of the employer’s time
risk event.1
However, if, for reasons within the employer’s control, the contractor is
prevented from completing by the date for completion and there is no right to
extend time for performance (or it is not properly extended) the employer can
no longer insist upon the completion date. It is then left without a firm date
from which liquidated damages might be calculated. Time is then said to be
‘at large’ as a result of the effect of what is known as the ‘prevention
principle’, which has been described as being based upon:
(i) a rule of law: ‘some broad notion of justice as that a man should not be
allowed to recover damages for what he himself has caused’;2 or
(ii) an implied term: ‘as a matter of fairness or policy’.3

The expression ‘time at large’ is thus usually used to indicate that the claimant
believes that, for one reason or another, there is no enforceable date for
completion of the works. Hence, because there is then no date from which
they can be calculated, the employer’s right to liquidated damages is defeated.
If that argument succeeds, the contractor’s obligation is to complete within a
reasonable time. If it does not then the employer may recover its losses as
general damages at common law.

There is some doubt as to whether, when the employer has lost its right to
liquidated damages, the fixed sum specified remains in limbo, as it were, to act

1 Balfour Beatty Buildings Ltd v Chestermount Properties Ltd (1993) 62 BLR 1,

QB (Comm Crt), Colman J, at page 29.
2 SMK Cabinets v Hili Modern Electrics Pty Ltd [1984] VR 391, Supreme Court of
Victoria, at page 395; also 1 Const LJ 159.
3 See note 2.
1
as a cap on recoverable losses as is sometimes thought.4 Alternatively,
whether it is void ab initio and hence of no effect at all, with the logical result
that the employer is then entitled to recover provable losses in excess of what,
at the time the contract was entered into, were agreed to be a limit on the
employer’s right to recovery.5 However, we are not concerned here with the
financial consequences of time at large. This paper is concerned only with the
circumstances in which the employer might find itself without an enforceable
completion date and the practical problem of then determining how a
reasonable time to complete might fairly be calculated.

Whether time has become at large is a matter of law dependant upon the terms
of the contract and the facts that are alleged to defeat the applicability of the
liquidated damages provisions. What is a reasonable time to complete once
time has become at large is a matter of fact depending upon the circumstances
as to how time has become at large, the date on which time became at large,
and the materials available from which such a calculation could properly be
made. It follows that the law and facts are inextricably bound and it is not
possible to deal with one aspect satisfactorily without also dealing with the
other.

So, before passing on to consider how a reasonable time to complete might be

calculated, it is helpful to consider how the parties might have come to be
without an enforceable completion date in the first place. In principle, there
are at least two possibilities as to how time may be at large.

First, there may be a contract completion date together with a number of

employer’s time risk events for which the contract makes provision for the CA
to extend time but which have not been operated because the power to extend
time:
(i) has been wrongfully exercised; or
(ii) has not been exercised at all; or
(iii) has become inoperable; or
(iv) does not apply to the occurrence in question; or
it cannot be applied because the parties have failed to specify a completion
date to which it can be applied; whilst unusual, this may occur if no date for
completion is written into the contract or, under the engineering forms, there is
no period for completion stipulated by either party.

4 See for example, IN Duncan Wallace QC, Hudson’s Building and Engineering
Contracts, 11th edition, 1995, Sweet & Maxwell, at para 10-002; Stephen Furst QC and
Vivian Ramsey QC, Keating on Building Contracts, 7th edition, 2001, Sweet &
Maxwell, at para 9-26; and John Dorter and John Sharkey, Building and Construction
Contracts in Australia, 2nd edition, 1990, at page 4749.
5 Adrian Baron, Damages in the shadow of a penalty clause – tripping over policy in the
search for logic and legal principle, Society of Construction Law (paper no 101), April
2002 and Hamish Lal, The doctrine of penalties and the ‘absurd paradox’: does it really
matter in 2003? Society of Construction Law (paper no 113), May 2003; both available
at wwwlscl.org.uk.
2
Alternatively, of course, there may not be a contract completion date simply
because there was no contract in the first place.

A power to extend time wrongfully exercised

Perhaps the most common allegation supporting a claim that time has become
at large is that the CA has either failed to grant an extension of time at all, or
that the extension of time that has been awarded is so unreasonable as to be
not within the CA’s power to make it. In Rapid Building Group v Ealing
Family Housing,6 for example, the Court of Appeal accepted that jurisdiction
as to the validity of a CA’s certificate could be dependant upon whether it
could be shown to be ‘legally invalid because given, for example, in bad faith
or in excess of his powers’.7

The principle on which such a claim is founded is that in leaving it to the CA

(who under some forms of contract is actually the ‘employer’s agent’8 or the
‘employer’s representative’9) to determine the contractor’s right to more time
(and hence the employer’s right to any liquidated damages), the CA is either
expressly or impliedly required that the extension of time awarded to the
contractor is fair and reasonable in all the circumstances.

In most modern standard forms of contract a perverse award by the CA will

not have the effect of defeating the employer’s right to liquidated damages and
set time at large simply because, by the terms of most of the standard forms,
the parties agree to refer their disputes to a tribunal that has the power to ‘open
up, review and revise’ any certificate so as to determine afresh the parties’
rights under the contract.10 The tribunal may then award a fair and reasonable
extension of time to the contractor and liquidated damages to the employer for
any delay in excess of that relieved by the extension of time.

On the other hand that may not always be so, particularly with bespoke forms
of contract that do not contain the same power to open up, review and revise.
In Peak v McKinney11 for example, it appears that the dispute was first decided
by an Official Referee. The Court of Appeal unanimously held that his
assessment of the cause of the delay to piling repairs was so perverse that it
did not amount to a decision on the facts, and they overturned it. In that case,
the Court of Appeal held that there had been delays caused by the employer
for which the contract provided no power to extend time. However,

6 Rapid Building Group Ltd v Ealing Family Housing Association Ltd (1984) 29 BLR 10,
CA, at page 14.
7 Northern Regional Health Authority v Derek Crouch Construction Co Ltd
[1984] QB 644; 26 BLR 1, CA, Browne-Wilkinson LJ at page 29.
8 Standard Form of Building Contract with Contractor’s Design, 1998 edition, Joint
Contracts Tribunal (JCT WCD ’98) and Conditions of Contract for Plant and Design-
Build, 1995 edition, International Federation of Consulting Engineers (FIDIC Yellow
Book).
9 ICE Design and Construct Conditions of Contract, 2nd edition, September 2001,
Institution of Civil Engineers.
10 See for example ICE Conditions of Contract, 7th edition, September 1999, Institution of
Civil Engineers, (ICE 7th), clause 66(11).
11 Peak Construction (Liverpool) Ltd v McKinney Foundations Ltd (1970) 1 BLR 111, CA,
at page 111.
3
Salmon LJ clearly thought that if the contract had contained a power to extend
time for the cause of delay, the failure to award an appropriate extension of
time under the circumstances would also have left the employer without an
enforceable completion date, which would have defeated the liquidated
damages provisions.12

Absence of power under the contract to extend time

In a contract that permits time to be extended, the prevention principle may
thwart the process in two ways:
(i) where there is no clause in the contract that permits the employer to
extend the time for completion for that particular occurrence; and
(ii) where, although there is a power to extend time for that occurrence, the
power cannot be exercised in the circumstances.

Where there is no clause in the contract

The leading case on this point is Peak v McKinney.13 A piling subcontractor
carried out defective work which had to be corrected but, before the repairs
were carried out, the employer wanted to have the various committees of the
Council and its own consultants’ advice, which took many months to obtain.
Because there was no clause in the contract between the employer and
contractor that permitted the employer to extend time for delayed approval of
the subcontractor’s repair process, the Court of Appeal held that the liquidated
damages clause was defeated. Salmon LJ put it thus:
‘The liquidated damages and extension of time clauses in printed forms
of contract must be construed strictly contra proferentem. If the
employer wishes to recover liquidated damages for failure by the
contractors to complete on time in spite of the fact that some of the delay
is due to the employers’ own fault or breach of contract, then the
extension of time clause should provide, expressly or by necessary
inference, for an extension on account of such a fault or breach on the
part of the employer.’14

This principle was also applied in Rapid Building Group v Ealing Family
Housing.15 The employer failed to grant exclusive possession of the site for a
period of three weeks (during which a couple resided with its dog in an Austin
Cambridge in a ‘significant portion of the site’) and where, because there was
no power to award an extension of time under the contract, there was no
completion date from which liquidated damages could run. Time was
therefore set at large.

The changes made to most of the standard forms of contract since JCT ’6316
provide that the employer may now extend the contractor’s time for

12 See note 11, at page 122.

13 See note 11.
14 See note 11, at page 121.
15 See note 6.
16 Standard Form of Building Contract, 1963 edition, Joint Contracts Tribunal (JCT 63).
4
performance for delay caused by events more widely described. Typically,
these provide for an extension of time to be granted under such anodyne
expressions as:
(i) ‘any act, neglect or default of the employer, the project manager or any
other person for whom the employer is responsible (not arising because
of any default or neglect by the contractor or by any employee, agent
or subcontractor of his)’;17
(ii) ‘a breach of contract on the part of the employer’;18
(iii) ‘any default, whether by act or omission, of the employer or any
persons for whom the employer is responsible in regard to the
project’;19
(iv) ‘any delay impediment prevention or default by the employer’;20
(v) ‘any act, instruction, default or omission of the employer, or of the
architect’;21
(vi) ‘any delay, impediment or prevention caused by or attributable to the
employer, the employer’s personnel or the employer’s other
contractors on the site’;22
(vii) ‘any breach of contract by the employer that is not one of the other
compensation events referred to’.23

As a result, it is now less likely (except in the case of a bespoke form that has
no such provisions) that circumstances within the control of the employer
could occur that were simply not contemplated as being excusable under the
contract.

Where the clause is inapplicable in the circumstances

The second common theme is that, whilst time to complete may legitimately
be extended, the circumstances at the operative time are such that they are
outside the administrative process contemplated. This may be because, for
example, the contract provides that an extension of time may only be granted
for the effect of variations instructed before the stipulated completion date. In
that case, time cannot be extended for the effect of variations instructed once
the completion date has passed.24

17 Contract for building and civil engineering works, with quantities, 1998 edition, PACE
(GC/Works/1), clause 36(2)(b).
18 Form of contract for lump sum contracts, 4th edition, 2001, Institute of Chemical
Engineers (IChemE Red Book), clause 44.1(d).
19 Standard Form of Management Contract, 1998 edition, The Joint Contracts Tribunal Ltd,
clause 2.13.2.
20 See note 10, clause 44(1)(e).
21 ACA Form of Building Agreement, 3rd edition, 1998, Association of Consultant
Architects, clause 11.5(e).
22 Conditions of Contract for Construction, International Federation of Consulting
Engineers, 1999 edition (the Red Book), clause 8.4(e).
23 NEC3 Engineering and Construction Contract, 2005 edition, Institution of Civil
Engineers, (ECC3), clause 60.1(18).
24 See note 2.
5
However, as a result of a recent arbitration in Hong Kong25 it would appear
that this is unlikely to be in point in relation to standard form contracts which
follow the typical Joint Contracts Tribunal (JCT) phraseology. The case was
in relation to the Hong Kong standard form (which closely follows the JCT
1963 edition). Neil Kaplan CBE QC determined that a power to extend time
if, as a result of events at the employer’s risk, completion was likely to be or
has been delayed beyond the completion date was broad enough to entitle the
architect to extend time for the effect of variation instructions issued after the
completion date had passed.

Alternatively, the right to extend the time for performance might be

conditional upon an administrative act (such as notice of delay being given by
the contractor) in the absence of which the power may be held not to arise.
Typically, this can be construed to affect interim extensions of time under a
number of standard forms of contract26 but not the power to reconsider
entitlement to an extension of time after completion has been achieved, which
commonly is not dependant upon notice.

A scenario such as this was considered in the Australian case of Gaymark v

Walter Construction.27 The standard form of Australian contract National
Public Works Contract 3 (1981)28 had been edited to provide, amongst other
things, that notice of delay was to be given not later than 14 days after the
cause of delay first arose, coupled with a condition that entitlement to an
extension of time was dependant upon the contractor complying strictly with
the notice provisions. The Supreme Court of the Northern Territory refused to
upset an arbitrator’s award which found that in the absence of compliance by
the contractor, the CA was not permitted to extend the time for completion.
Accordingly, because at least some of the delay to completion was caused by
the employer, the completion date was then unenforceable and the right to
liquidated damages was lost.

The correctness of this case has been doubted.29 It is apparent that on its facts
it was not the employer’s breach (of which the employer wrongly attempted to
take advantage) so much as the contractor’s breach (in not giving notice)
which, according to the arbitrator’s decision, left the contractor in a better
position than it would have been had it given notice.30

25 See (2005) 21 Const LJ 321 for the award on the preliminary issue, which usefully
discusses the results of other arbitrations on similar facts.
26 See for example Standard Form of Building Contract, Private with Quantities, 1998
edition, The Joint Contracts Tribunal Ltd (JCT 98), clause 25.3.1
27 Gaymark Investments Pty Ltd v Walter Construction Group Ltd (1999) NTSC 143,
(1999) 16 BCL 449.
28 Known as NPWC3.
29 See for example IN Duncan Wallace QC, ‘Prevention and Liquidated Damages: a
Theory Too Far?’ (2002) 18 Building and Construction Law 82 and Hamish Lal,
Extensions of time: the conflict between the prevention principle and notice requirements
as a condition precedent, Society of Construction Law (paper no 103), April 2002,
available at www.scl.org.uk.
30 The evil which Vinelott J sought to avoid by rejecting an implied term in JCT 63 to the
same effect in London Borough of Merton v Stanley Hugh Leach Ltd 32 BLR 51,
(1986) 2 ConstLJ 189, ChD.
6
In general terms the effect of Gaymark v Walter Construction is that the
prevention principle overrides the requirement for notice as a condition
precedent. This is contrary to the views express by the Supreme Court of
Victoria in SMK Cabinets v Hilli.31 The Supreme Court of New South Wales
has also declined to accept that a failure by the contractor to give notice in a
contract that rendered notice a condition precedent to entitlement would
automatically deprive the employer of liquidated damages. In the case of
Turner Corporation v Austotel Cole J rejected this contention saying:
‘If the Builder, having a right to claim an extension of time fails to do so,
it cannot claim that the act of prevention which would have entitled it to
an extension of time for Practical Completion resulted in its inability to
complete by that time. A party to a contract cannot rely upon preventing
conduct of the party where it failed to exercise a contractual right which
would have negated the effect of that preventing conduct.’32

Turner v Austotel was also referred to by the New South Wales Court of
Appeal in the case of Peninsula Balmain v Abigroup, in which it was observed
obiter that:
‘… in the absence of the supervising officer’s power to extend time even
if a claim had not been made within time, the contractor would be
precluded from the benefit of an extension of time and liable for
liquidated damages, even if delay had been caused by variations required
by Peninsula [the employer] and thus within the so called “prevention
principle”.’33

There should be nothing in the employer’s control that could permit the
employer to require the contractor to take more time to complete, whilst at the
same time taking liquidated damages for the contractor’s failure to complete
on time. However, there is something intuitively disturbing about the concept
of the contractor’s failure to comply with a condition precedent to an
extension of time interfering with the employer’s entitlement to liquidated
damages so as to render the contractor better off by not complying with the
contract than it would have been if it had.

This is not a subject that has yet come before the English courts. It can though
be expected to occur sooner or later under a number of domestic and
international standard forms of contact. For example:
(i) PPC2000 states that the employer may only grant an extension of time
if there is a breach of contract by the employer or any consultant ‘of
which the Constructor has given Early Warning’;34
(ii) NEC3 states: ‘if the contractor does not notify a compensation event within
eight weeks of becoming aware of an event, he is not entitled to a change in

31 See note 2, Brooking J at page 395.

32 Turner Corporation Ltd v Austotel Pty Ltd (1997) 13 Building and Construction
Law 378, Supreme Court of New South Wales, at pages 384-385.
33 Abigroup Contractors Pty Ltd v Peninsula Balmain Pty Ltd [2002] NSWCA 211, (2002)
Building and Construction Law 322, New South Wales Court of Appeal, at para [78].
34 Standard Form of Contract for Project Partnering, Association of Consultant Architects
and Trowers + Hamlin (PPC 2000), clause 18.3(xiv).
7
 the prices, the completion date or a key date unless the project manager
35
should have notified the event to the contractor but did not’;
(iii) and the 1999 editions of the FIDIC forms also provide, perhaps less
enigmatically, that: ‘if the contractor fails to give notice of a claim within 28
days, the time for completion shall not be extended, the contractor shall not
be entitled to additional payment, and the employer shall be discharged from
36
all liability in connection with the claim.’

Absence of a contract requiring performance by a certain date

This may occur when, although there is a contract, there has never been a
contract completion date agreed, or if - whilst the parties perform as though
there were a contract in existence - there is nothing by which a contract can be
construed. In neither case is it possible to find a date by which the contractor
is bound to perform. For example, in British Steel Corporation v Cleveland
Bridge and Engineering,37 no formal contract was ever signed. The steel was
delivered but the contractor refused to pay, saying that late and out of
sequence delivery had caused them loss and that such late delivery was a
breach of contract. The subcontractor claimed that there could be no
contractual delivery date as there was no contract. Goff J (as he then was)
observed:
‘Both parties confidently expected a formal contract to eventuate. In
these circumstances, to expedite performance under that anticipated
contract, one requested the other to commence the contract work, and the
other complied with that request. If thereafter, as anticipated, a contract
was entered into, the work done as requested will be treated as having
been performed under that contract; if, contrary to their expectation, no
contract was entered into, then the performance of the work is not
referable to any contract the terms of which can be ascertained ...’38

Take similar circumstances where, notwithstanding that nothing had been

agreed as a contract period, in the course of negotiations the contractor had
indicated what it thought was an adequate completion period. Then, in the
absence of anything that would indicate the contractor to be at fault, it would
appear that that may be construed as a reasonable starting point from which to
construe a duration for the scope of the contract works – but not a baseline for
the purposes of extending time under the contract. For example, in J & J Fee
v Express Lift39 HH Judge Bowsher QC gave a provisional view on the
documents before him (without deciding) that it would be impossible for the
contractor to contend that a reasonable time for completion of the works
would be any later than the date they had consistently put forward in contract
negotiations.

35 See note 23, clause 61.3.

36 See note 22, clause 20.1.
37 British Steel Corporation v Cleveland Bridge and Engineering Company Ltd
[1984] 1 All ER 504, QBD.
38 See note 37, at page 511b.
39 J & J Fee Ltd v The Express Lift Company Ltd (1993) 34 Con LR 147, QBD (OR).
8
Identifying a reasonable time to complete
There is some judicial support for the view that provided that the contract
contained a completion date, or a completion date could be construed from the
conduct of the parties, then that is the position from which to commence. For
example, in J & J Fee v Express Lift40 there had been correspondence between
the parties on the date of commencement and completion. The last
correspondence from the contractor stated that it could see little possibility of
improvement on the dates previously given, but suggested that the situation be
monitored and if it became possible to review the situation then it would try to
improve upon it. In this case the court thought that the completion date for the
contract works would not be any later than the date they had consistently put
forward in contract negotiations.
In Astea v Time Group, HH Judge Seymour QC also seemed to think that the
contractor’s ‘contract period’ was the appropriate starting point, in saying that
consideration of a reasonable time for performance: ‘…is likely to include
taking into account any estimate given by the performing party of how long it
would take him to perform …’.41 In other words, having identified a date by
which the contract works were to be completed, the reasonable time to
complete can be calculated from that baseline.
There are then two positions to consider: whether the time risk structure under
the contract subsists notwithstanding the absence of a completion date or,
whether the time risk structure falls with the completion date.

A contract with an enforceable risk structure

In these circumstances the contractor may be entitled to the contract period
together with any additional time caused by the employer’s time risk events
stipulated under the contract (which, depending upon the contract may include
everything that is beyond the contractor’s control). As Hudson suggests:
‘It also seems possible that, in deciding on a reasonable time for
completion in such a case, there should be consideration of the
circumstances stipulated in any contractual extension of time clause as
justifying an extension of time, either as indicating circumstances which
should be taken into account, or possibly as excluding any circumstances
not mentioned in the clause.’42

In Peak v McKinney, for example, the view was expressed that, ‘… the
problem can be cured if allowance can be made for that part of the delay
caused by the actions of the employer ...’43

In Rapid Building Group v Ealing Family Housing it was also thought that the
risk structure of JCT ’6344 might survive the CA purporting to grant an

40 See note 39.

41 Astea (UK) Ltd v Time Group Ltd [2003] EWHC 725, TCC, at para 144.
42 See note 4, Hudson, at para 9.031.
43 See note 11, Phillimore LJ at page 127.
44 See note 16.
9
extension of time for the failure to give possession on time for which, under
JCT ’63, he had no power. In this case Lloyd LJ remarked:
‘Like Phillimore LJ in Peak v McKinney, I was somewhat startled to be
told in the course of the argument that if any part of the delay was caused
by the employer, no matter how slight, then the liquidated damages
clause in the contract … becomes inoperative.
I can well understand how that must necessarily be so in a case in which
the delay is indivisible and there is a dispute as to the extent of the
employer’s responsibility for that delay. But where there are, as it were,
two separate and distinct periods of delay with two separate causes, and
where the dispute relates only to one of those two causes, then it would
seem to me just and convenient that the employer should be able to claim
liquidated damages in relation to the other period.’45

A similar view seems to have been taken in SMK Cabinets v Hili.46 Whilst
acknowledging that the prevention principle was grounded upon
considerations of fairness and reasonableness, Brooking J concluded that the
employer’s act of prevention only served to prevent the employer from taking
liquidated damages that accrued after the employer’s breach. In that case, the
absence of a power to extend time for a variation given after the completion
date had passed did not upset the parties’ contractual rights and obligations
accruing prior to the date upon which the instruction was given.

Where this approach is appropriate, the calculation of a reasonable time to

complete is exactly the same as if the contract period had been properly
extended. The burden of proving a reasonable time then falls on the contractor
to show what time (additional to that which it initially contracted for) it
reasonably needs to cover the delaying effect of both the employer’s breach
and those employer’s risks under the contract.

Then the only difference between a properly extended time for completion
under the contract and a reasonable time to complete outside the contract, is
that after the former the employer is entitled to liquidated damages for delay.
After the latter, on the other hand, it is no longer entitled to liquidated
damages but must prove its actual losses and, in the SMK Cabinets v Hili
case,47 only the actual losses flowing from the breach.

A contract with a risk structure that lapses

The argument in favour of the risk structure lapsing is that as it is the
employer’s breach that has set time at large; the employer should not be
entitled to maintain its right under the contract for the contractor to prove its
entitlement to any more time that it needs. In those circumstances, so the
argument runs, the burden of proof should shift to the employer to show that
the time actually taken is unreasonable in all the circumstances that then exist.

45 See note 6, at page 19.

46 See note 2.
47 See note 2.
10
Then the contractor should be entitled to the time it has actually taken to
complete, unless the employer can show otherwise.

Where there is an agreed duration for the contract scope of works but the
effect of an act of prevention is assumed to dispense with the apportionment of
time risk under the contract, there are thus two possibilities to consider. They
are (a) whether the contractor should be entitled to the time the work should
have taken, together with the time necessary for those matters beyond the
contractor’s control, or (b) all the time the work actually took, less only the
time taken up by those matters within the contractor’s control.

In other words, the contractor gets either the contract period together with
whatever it can prove should be added on for those events that can be shown
to be outside its control; or it gets everything, unless the employer can prove
something should be deducted for the effect of those events within the
contractor’s control.

In the first case the contractor may have the benefit of additional time for such
events as adverse weather, strikes, lock-outs, civil commotion, force majeure,
and so on, which are not ipso facto employer’s breaches and which are beyond
the contractor’s control. However, delay caused by the contractor’s
subcontractors and suppliers for example, may be construed to be beyond or
within the contractor’s control depending upon the factual circumstances.
Although most factors beyond the contractor’s control may well serve to
justify an extended construction period, factors that the parties expressly or
impliedly had in mind at the time of the contract (for example, the economic
climate and general availability of labour, plant and materials) can be expected
to have a bearing upon the time actually taken.

In the second case, the contractor will be entitled to additional time for
everything unless it can be shown to arise out of a breach on the part of the
contractor. The effect of this scenario is that the contractor is entitled to all the
time the works actually take to complete, less the time for the acts or
omissions that amount to a breach on the part of the contractor.

Amongst other things, such considerations might reasonably encompass, for

example, whether or not the contractor had in all the circumstances:
(i) carried out the work with adequate materials goods and workmanship
which did not prove defective;
(ii) arranged deliveries so that materials, goods, plant and other resources
were available when needed;
(iii) expressly or impliedly warranted its ability to maintain progress in a
particular situation or at a particular speed;
(iv) had adequate site organisation, labour force, plant and materials; and
(v) remained responsible for acts or omissions within the control of the
contractor’s subcontractors and suppliers, notwithstanding that they
may not have been within the direct control of the contractor.

11
Whilst the Court of Appeal did not express a view on what would be a
reasonable time to complete, and no view was expressed upon whether the risk
structure should remain, in Peak v McKinney Salmon LJ appeared to take the
view that the principle issue was how much delay was caused by the
employer’s breach.48 In other words, how much the contractor could
demonstrate should be added on to its contract period. On the other hand,
whilst accepting that was a consideration, Edmund Davies LJ seemed to think
that the time taken up by those matters within the contractor’s control was a
relevant consideration, saying:
‘But, just as the plaintiffs must themselves be absolved from contributing
to any delay, so also must the defendants, save in respect of that for
which inevitably flowed from their original default.’ [emphasis added]49

Relieving the contractor from the effect of everything other than that which is
within the contractor’s control is also the route that the courts appear to have
taken in a few cases of time at large in fields other than construction. For
example, take the shipping case of Pantland Hick v Raymond & Reid.50 The
consignee of a cargo was in breach of a contractual obligation to discharge the
relevant vessel within a reasonable time. There was a single cause of delay,
namely a strike of dockworkers, over which the consignee had no control and
the effect of which, while it lasted, was totally to prevent performance of the
contract. The appellant’s case was that the appropriate period was the
additional time that would have been required for the effect of the strike, over
and above the contract period. But the respondents argued that the question
was not what time would have been reasonable under ordinary circumstances,
but what time was reasonable under the circumstances as they then were,
absent any fault on the part of the respondents. The issues were rationalised
by Lord Herschell as follows:
‘My Lords, there appears to me to be no direct authority upon the point,
... I would observe, in the first place, that there is of course no such
thing as a reasonable time in the abstract. It must always depend upon
circumstances. Upon ‘the ordinary circumstances’ say the learned
counsel for the appellant. But what may without impropriety be termed
the ordinary circumstances differ in particular ports at different times of
the year. … It appears to me that the appellant’s contention would
involve constant difficulty and dispute, and that the only sound principle
is that the ‘reasonable time’ should depend on the circumstances which
actually exist. If the cargo has been taken with all reasonable despatch
under those circumstances I think the obligation of the consignee has
been fulfilled. When I say the circumstances which actually exist, I, of
course, imply that those circumstances, in so far as they involve delay,
have not been caused or contributed to by the consignee.’51

48 See note 11, at page 120.

49 See note 11, Edmund Davies LJ at page 124.
50 Pantland Hick v Raymond & Reid [1893] AC 22, HL.
51 See note 50, Lord Herschell at page 29.
12
In the same case, Lord Watson took the view that, by analogy, the contractor
would only be disentitled to more time with regard to events that were both
beyond the contractor’s control and were neither negligent nor unreasonable.52

In Astea v Time Group, a case which involved the development of computer

software, HH Judge Seymour explained the decision in Pantland, saying:
‘What it seems to me the application of the test formulated by the House
of Lords in Pantland Hick v Raymond & Reid involves in a case such as
the present is a broad consideration, with the benefit of hindsight, and
viewed from the time as at which one party contends that a reasonable
time for performance has been exceeded, of what would, in all the
circumstances which are by then known to have happened, have been a
reasonable time for performance.’53

On the broad ‘considerations of fairness and reasonableness’ as being the

foundation of the prevention principle (enunciated by Brooking J in SMK
Cabinets v Hili54), it thus seems wrong to deprive the contractor of a right to
relief in time as a result of the employer’s breach, which otherwise the
contractor would have enjoyed under the risk provisions of the contract. The
better view, it seems, is that a reasonable time to complete should not so much
be based upon ‘circumstances beyond the contractor’s control’ but along the
line taken by Lord Herschell in Pantland Hick55 and Judge Seymour in Astea v
Time Group.56 That is, by subtracting from the time actually taken the time to
execute circumstances expressly or impliedly within the contractor’s control
that have caused or contributed to the delay to completion. Accordingly, if the
risk structure falls, then it would appear to be appropriate that the onus of
proving a reasonable period to complete should lie with the employer.

The absence of a contract

If there is no contract, there can obviously be no risk structure under the
contract. A reasonable time to complete where there is no contract can only
be determined by assessing what would have been the completion date but for
those events for which the contractor is not entitled at common law to be given
more time. Whilst the calculation is easy enough, provided the data is
available on which to make the calculation, in many cases in which there is no
contract, it is highly likely that there will be no programme and few if any as-
built records from which to prepare one.

Whilst there may not be many circumstances in which a reasonable time to

complete in tort is applicable, it has been found to be of practical importance
in the case of an occupier of business premises interfered with by repairs
carried out by others taking longer than was reasonable to complete.

52 See note 50, at pages 32 and 33.

53 See note 41, at para 144.
54 See note 246.
55 See note 50.
56 See note 41.
13
Proving the effect upon the critical path
Where an implied ‘contract period’ can be established to which the effect of
the employer’s delays can be added, in some contracts it would be entirely
possible to take the contractor’s planned programme for the contract scope as
a baseline. Added to it would be the putative effect of the employer’s breach,
together with (where appropriate) the putative effect of the employer’s time
risk events under the contract and that of any breach. In practical execution
this would be an as-planned impacted analysis. It is the type of analysis
adopted to prove the contractor’s entitlement to an extension of time in John
Barker Construction v London Portman Hotel where, although there was a
contract programme, there were no as-built records.57 The effect of this is to
entitle the contractor to what the contractor claims to be the gross effect of the
employer’s risk events on the contractor’s programme for the works,
regardless of whether it actually followed that programme and regardless of
any culpable delay by the contractor.58

So far as concerns time at large calculations, one of the perceived difficulties

with this is that the contractor’s programme (even if well thought out, fully
logic-linked and resource-calculated, without any contractor’s time
contingencies (which most are not)) at its highest only represents the
contractor’s intent. It is a manifestation of an intent which in most forms of
contract is not binding upon the contractor. There are usually many other
mixtures of resources, durations and logic available which would have
achieved the same end-date but which might not illustrate the same predicted
effect of the employer’s risk events or breaches.

Provided the materials are available with which to do it, a reasonable time to
complete can also properly be calculated by the time impact method. That is,
on the basis of the affect, from time to time, of each time risk event or act of
prevention as it impacted the contractor’s contemporaneous planned critical
path to completion, absent any identifiable time contingency. This is the
method acknowledged by the Society of Construction Law’s Delay and
Disruption Protocol59 as being the most thorough and is that implied to be an
appropriate method of calculating an extension of time by HH Judge LLoyd in
Balfour Beatty Construction v London Borough of Lambeth60 and by HH
Judge Seymour in Royal Brompton Hospital v Hammond.61

By taking into consideration the contractor’s culpable delay (if any) and
identifying the net effect of the employer’s acts or omissions on the
contractors contemporaneous programme, the contractor does not benefit from

57 John Barker Construction Ltd v London Portman Hotel Ltd (1996) 83 BLR 31, TCC.
58 A contingency that rightly renders this method unsuitable where as-built records are
available. See for example, Great Eastern Hotel Company Ltd v John Laing
Construction Ltd [2005] EWHC 181, TCC, at para 184.
59 Delay and Disruption Protocol, Society of Construction Law, October 2002, available at
www.eotprotocol.com.
60 Balfour Beatty Construction Ltd v London Borough of Lambeth [2002] 1 BLR 288, TCC,
at page 302.
61 Royal Brompton Hospital NHS Trust v Frederick A Hammond (No 1) [2000] EWHC
Technology 39, at [32].
14
additional time other than that caused by the employer’s time risk event or
breach. So, say the contractor is in culpable delay as a result of not being able
to obtain sufficient labour, there are no other events and the only breach is a
variation. The contractor would only be entitled to the putative effect of the
variation on the programme it was then following in addition to the contract
period and no more, regardless of how long the works actually took to
complete.

In both these scenarios the burden of proof as to entitlement rests with the
contractor. However, it is thought that where the employer has either not
stipulated a date for completion, or by its own acts prevented the due date
from being achieved, it should not be for the contractor to prove what period
of time it is entitled to: it should be for the employer to demonstrate that the
time actually taken by the contractor is excessive in all the circumstances.

In the absence of a contract period from which to start, a reasonable time to

complete can only properly be calculated by the As-Built But-For method (see
below), on the basis of the actual effect of each breach by the contractor as it
impacted the contractor’s contemporaneous critical path to completion. This
is one of the methods recognised by the SCL Delay and Disruption Protocol
as being an appropriate method of calculating an extension of time in the
absence of a competent planned programme. Provided the materials are
available from which to calculate it, this method takes as a base line the
programme of the work as it was actually carried out, and subtracts from the
critical path those actual periods of time for which the contractor is liable. In
so far as, in the absence of those time periods, the critical path shortens, then
the resultant completion date can be said to be the completion date that
reasonably could have been achieved in all the circumstances then existing,
save for the contractor’s culpable delay.

One of the essential characteristics of a tort is that it arises out of man’s actual
conduct rather than out of an agreement for future conduct from which a
planned intent can be deduced. This therefore also tends to be the most likely
method available for calculating an appropriate time to complete where the
claim is based upon a tortious relationship, for example, in nuisance.

A worked example
The claim
On 27 May 1997, the party responsible for the repair of a building became
aware of spalling concrete cladding panels. A protective fan scaffold was
erected in October 1997 and remained in place until 18 April 1999, when it
was dismantled and replaced to enable the necessary works to be carried out.
The claimant’s case was that the erection and maintenance of the scaffolding
exceeded the period which was necessary for the purposes of carrying out the
works required and that, as a result of the nuisance caused, it lost profits
between October 1997 and April 1999.

15
The method
The dispute related to the actual length of time the scaffolding remained in
place outside the claimant’s place of business whilst investigation and repairs
were carried out.

The necessity for the repairs was unplanned and there could never have been a
planned programme for the incident or its investigation prior to the letting of
the repair contract. There were, however, documents available giving an
historical record of the sequence of occurrences from the date the claimant
was notified of the spalling concrete, to the date the repair contract was
awarded. An appropriate method of analysis would thus be one that used the
actual sequence of works as the baseline.

The measurement of unnecessary delay is made by reference to what would

have been the completion date but-for any delaying event (deduced from the
re-created history of occurrences in the form of a dynamic programme). This
form of analysis is called an As-Built But-For (‘ABBF’) analysis or a
collapsed as-built. It requires the logic by which the works were procured to
be deduced from the sequence that the activities actually followed.

The method of creating the factual baseline is as follows:

(i) build the programme from the documents, creating milestone activities
which indicate start or completion of an activity;
(ii) identify the actual time periods for each activity;
(iii) link the actual time periods represented by the activities with their
perceived logical predecessors and successors;
(iv) identify the activities that represent periods of time that were
unnecessary to the process and code the difference between a
reasonable duration and the actual duration as delaying events.

The ABBF method is as follows:

(i) for the purposes of collapsing, take the baseline as-built programme
and copy it to a new programme file for the ABBF analysis;
(ii) calculate the critical path to completion (this is done automatically by
the software when the command to re-sequence is given);
(iii) for the identified delaying events on the programme attribute the
duration of zero days in place of their actual duration;
(iv) recalculate the critical path and identify the date the completion date
would have occurred but for the delaying events.

If any delaying event was found to be at any point in its duration on or near
the critical path, the completion date will be brought forward when the
duration of the delaying event is reduced to zero days. The difference between
(i) the completion date with the actual duration of the delaying event and (ii)
that as a result of the collapse of the critical path with the duration of the event

16
set to zero days is the delay to the completion date actually caused by the
delaying events.

The delaying events

Event 1: Delay in obtaining recommendation for investigation
On 27 May 1997 the repairer was advised that spalling concrete cladding
panels were a hazard to members of the public. No action was taken,
and in June 1997 the building owner obtained proposals for an inspection
and survey by their engineers.
Between 10 and 15 days would be a reasonable period for the repairer to
have arranged for a survey and inspection to have been carried out, so a
report should have been available by 9 June 1997.
The repairer took no action on the building owner’s request until they
responded on 1 July 1997, the report being finally produced on 14 July,
causing 15 working days delay to progress.62

Event 2: Delay in ordering detailed investigation

Absence of any progress with repairs resulted in the owner’s engineers
carrying out a structural survey commencing on 2 October 1997.
This is the period of delay during which the repairer appears to have
been inactive prior to the date on which the owner’s engineers were
instructed to carry out further investigations. It caused 46 working days
delay to progress.63

Event 3: Further delay in the repairer instructing their engineers

On 3 October 1997, the owner’s engineers recommended the installation
of a scaffolding arrangement which would tie back the spalling concrete
panels to the inside face of the building’s edge columns, and this
recommendation was faxed to the repairer on the same day.
The repairer’s solicitors confirmed that the repairer’s engineers had
inspected the building on Saturday 4 October 1997. The repairer’s
engineers and the owner’s engineers then carried out a joint inspection
on 7 October 1997.
On 8 October 1997 the repairer’s engineers recommended a fan scaffold
arrangement be installed, quotations for which were submitted to the
repairer on 14 October 1997.
The difference between becoming aware of the owner’s engineers
surveys, until the repairer’s engineers were instructed, represents a delay
to progress of 2 working days.64

62 Representing the period from 10 to 30 June 1997.

63 Representing the period from 1 July to 3 September 1997.
64 Representing the period form 3 to 6 October 1997.
17
Event 4: Delay in panel removal for inspection
The owner’s engineers planned to remove one cladding panel for further
inspection purposes over the weekend of 4-5 October 1997. This date
then slipped to 12 October 1997, and then to 19 October 1997. Further
slippage occurred and the panel was actually removed on 2 November
1997; this caused 29 working days delay to progress.65

Event 5: Delay in instructing contractors to proceed with scaffolding

The repairer’s engineers obtained quotes from two scaffolding
contractors and forwarded these to the repairer on 14 October 1997. On
the same day the repairer requested that the repairer’s engineers place an
order with the scaffolding contractor. However, the repairer’s engineers
did not instruct the scaffolding contractor to proceed until 16 October
1997, losing 2 more working days progress.66

Event 6: Delay in start of scaffold erection

The scaffolding contractor’s quotation for the supply and installation of
the scaffold stated that a one week lead-in time was required between an
instruction to proceed and the start of scaffold erection. On 16 October
1997 the repairer’s engineers instructed the scaffolding contractor to
proceed, so the contractor should have commenced work on 23 October
1997. Records indicate that the scaffolding contractor applied for a
licence to erect scaffolding on 24 October 1997 and that scaffold
erection actually commenced on 27 October 1997, losing 2 more
working days progress.67

Event 7: Delay in scaffold erection duration

The scaffolding contractor’s quotation stated that the scaffold would take
8 days to erect. Records indicate that scaffold erection commenced on
27 October 1997. Based on Monday to Friday working, the scaffolding
should have been completed on 5 November 1997. It was completed on
6 November 1997, representing 1 more working day’s delay to progress.

Event 8: Delay in the repairer’s engineers preparing a preliminary repair

strategy
The repairer’s engineers should have continued with the preparation of
repair options, which should have taken between 2 and 3 weeks and, at
the latest should have been completed by 5 November 1997.
The repairer’s engineers did not issue their preliminary repair proposals
to the repairer until 20 November 1997, causing a delay to progress of
another 10 working days.68

65 Representing the period from 4 October to 1 November 1997.

66 Representing the period from 14 to 15 October 1997.
67 Representing the period from 23 to 24 October 1997.
68 Representing the period from 6 to 19 November 1997.
18
Event 9: Delay in forwarding test report to the repairer’s engineers
The owner’s engineers issued the inspection report on 5 November 1997,
but did not issue a copy to the repairer or the repairer’s engineers. On 18
November 1997, the repairer’s engineers requested a copy of the
inspection report, which contained chemical test results and without
which they were not able to finalise their proposals. The report should
have been delivered within 3 days but was not received until 15
December 1997.
Until the repairer’s engineers received a copy of the report, they could
not finalise their design options and the detailed design phase of the
works could not commence. Thus, the delay in issuing a copy of the
report to the repairer’s engineers caused an additional 35 working days
delay to progress.69

Event 10: Delay in preparing the owner’s dilapidations schedule

The Section 146 notice required the repairer to undertake repair works in
accordance with the terms of their lease. The earliest the dilapidations
schedule could have been issued was 9 December 1997. However, the
dilapidations schedule was not issued until 9 January 1998, causing
another 19 working days delay to progress.70

Event 11: Delay in reviewing engineers report and carrying out additional
testing
The owner’s report said that it was not feasible to repair the cladding
panels and recommended that they be removed and replaced.
The repairer and their engineers disagreed with these recommendations
and through January 1998 continued to obtain quotes for over-cladding
the existing panels. The repairer’s engineers also recommended further
tests, which were expected to take a further 3 weeks.
On 3 March 1998 the repairer reached the same conclusion as that of the
owner’s engineers – that the cladding panels had to be replaced. This
was confirmed by the repairer’s solicitors on 6 March 1998, who also
advised that the replacement works would take 6 months.
The delay in concurring with the findings of the owner’s engineer’s
report to enable the repairer’s engineers to finalise the design for the
cladding replacement and commence detailed design, caused 53 more
working days delay to progress.71

Event 12: Delays in the repairer instructions to architects

It appears that after the Section 146 notice was issued to the repairer on
23 January 1998, the repairer first considered appointing an architect. A
reasonable time for the repairer to appoint an architect would have been

69 Representing the period from 8 November (3 days after the 5th) to 12 December 1997;
however, if this event was held to be not one for which the repairer is liable, it would not
be collapsed in the ABBF analysis.
70 Representing the period from 10 December 1997 to 8 January 1998.
71 Representing the period from 15 December 1997 to 2 March 1998.
19
 within a week of receipt of the Section 146 notice, ie by 30 January
1998. However, a letter from the architect dated 2 March 1998 suggests
that the repairer’s first instructions to them were given at a meeting of 26
February 1998, which included a visit to the site and preparation of re-
cladding proposals. There was thus a delay to progress of 19 working
days in instructing the architect to design the replacement cladding.72

Event 13: Delay in revising scheme proposals after meeting with the planning
authority
Preparation of preliminary design options and cost estimate and a review
of these options by the repairer would probably be required prior to a
meeting with the planning authority which took place on 12 March 1998.
On 19 March 1998, the repairer advised that their planned timetable for
obtaining planning permission was 2 weeks of negotiations with the
planning authority prior to submission of the planning application,
followed by 8 weeks to obtain planning permission. It is reasonable to
expect the repairer’s engineer to have incorporated the feedback from the
planning authority, and prepared and issued further cost estimates and
scheme design for planning purposes to the repairer within 7 to 10 days.
Accordingly the scheme proposals following the 12 March 1998 meeting
should reasonably have been completed by 26 March 1998.
However, the architects did not complete their report on scheme
proposals for planning purposes until 20 April 1998, causing a delay to
progress of another 16 working days.73

Event 14: Delay in submitting planning application

The repairer intended that after 2 weeks of further negotiations following
the meeting with the planning authority, a planning application would
have been ready for submission in early April 1998. However, the
planning application was not submitted until 18 September 1998. This
caused a further delay to progress of 99 working days.74

Event 15: Increased duration of design phase

On 19 March 1998, the repairer advised that the design and approval
phases, preparation of tender documentation and tender period would
proceed in parallel with the process of obtaining planning permission,
over a 10 week period.
It would thus be reasonable to expect the 4 week design phase and
subsequent approval to have commenced following the architects’
scheme proposals of 20 April 1998. This corresponds to production of
the tender documents commencing 6 weeks later on 1 June 1998.
The delay to the start of preparation of the tender documents on 28
October 1998 was caused by an increase in the duration of the design

72 Representing the period from 30 January to 25 February 1998.

73 Representing the period from 27 March to 17 April 1998.
74 Representing the period from 4 May to 17 September 1998; the start of the delay to
progress is determined as two weeks from 20 April 1998 which from Event 13 is the
additional time taken to produce scheme designs for planning purposes.
20
 approval period while the repairer continued to explore repair options
rather than proceed with the cladding replacement option. This resulted
in another delay to progress of 107 working days delay to progress.75

Event 16: Delay in production of tender documents

The tender document preparation commenced on 28 October 1998, and
should have been completed on 3 November 1998. However, tender
documents were not complete until 15 December 1998 and tenders were
invited on 16 December 1998, causing a delay to progress of 30 more
working days.76

Event 17: Delay in granting planning permission

The repairer’s planning application was made on 18 September 1998 and
with the statutory 8 weeks period for consideration, planning permission
should have been received by 12 November 1998. Planning permission
was actually granted by the planning authority on 17 November 1998,
causing a delay to progress of another 2 working days.77

Event 18: Increased duration of tender period

On 19 March 1998 the repairer advised that the tender period would be 3
weeks. Tenders were invited from 5 contractors on 16 December 1998
and returned on Monday 25 January 1999, causing a delay to progress of
7 more working days.78

Event 19: Delay in tender evaluation

The tender evaluation period from receipt of tenders to placement of a
contract was 2 weeks, corresponding to a contract award date of 8
February 1999. However, the tender evaluation was not completed until
22 February 1999, recommending the award of the contract. This caused
a further delay to progress of 10 working days.79

Event 20: Delay in contract award – resolution of cladding system

The recommendation for award of contract made on 22 February 1999
did not result in a contract until 29 March 1999.
It appears that the repairer decided not to award the contract until the
cladding design colour had been approved by the owner and planning
authority on 29 March 1999. However, the repairer could have finalised
the cladding choice prior to the tender evaluation period or after contract,

75 Representing the period from 1 June to 27 October 1998.

76 Representing the period from 4 November to 15 December 1998; however if this event is
held to be not within the repairer’s control it would not be collapsed in the ABBF
analysis.
77 Representing the period from 13 to 16 November 1999 (includes weekend of 14-15
November).
78 Representing the period from 14 to 22 January 1999.
79 Representing the period from 8 to 19 February 1999.
21
 and if they had done so, this delay to progress of 25 working days would
not have occurred.80

Results
A number of the delaying events occurred over the same time frame, in whole
or in part, and were thus parallel causes of the same delay to progress. The
ABBF analysis demonstrates that the earliest date on which repair works could
have been started but for all the delaying events when taken together was 23
January 1998. However, the repair works were not actually commenced until
18 April 1999.

Accordingly, the unnecessary delay in commencing the repair works amounts

to 450 calendar days. For this period, liability is, of course, to be established.
For example, the repairer may not be held to be responsible for the effect of
delay to progress caused by the owner81 or the inaction of the planning
authority82 and to that extent, the period against which the claimant’s losses
are calculated may be something less than the total avoidable delay caused.

Conclusion
This is an example of how the effect of Lord Herschell’s ratio83 might
reasonably be put into practice in determining a reasonable time to complete in
relation to a claim in tort. However, provided the materials are available from
which the factual matrix can be inferred, it is equally applicable to
construction disputes in which there is no contract or, if a contract, no
programme which might usefully serve as a baseline.

Keith Pickavance is an architect, chairman of Pickavance Consulting Ltd

and author of Delay and Disruption in Construction Contracts (3rd edition
2005); Wendy MacLaughlin is an engineer and senior analyst with
Pickavance Consulting Ltd.

© Keith Pickavance, Wendy MacLaughlin and the Society of Construction

Law 2005.

The views expressed by the authors in this paper are theirs alone, and do not
necessarily represent the views of the Society of Construction Law or the editor.
Neither the authors, the Society, nor the editor can accept any liability in respect of
any use to which this paper or any information or views expressed in it may be put,
whether arising through negligence or otherwise.

80 Representing the period from 22 February to 26 March 1999.

81 See Event 9.
82 See Event 17.
83 See note 50, at page 29.

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