BLOs and adjudication: the TCC doubles down on enforcement

The TCC has now reinforced the strength of adjudication-backed building liability orders. In Crest Nicholson Regeneration Ltd v Ardmore Construction Ltd (in administration) [2026] EWHC 1069 (TCC), Constable J has refused a stay of execution and additional time to pay the £14.9m adjudication liability imposed on Ardmore’s associates via a BLO under the Building Safety Act 2022. The court emphasised the “pay now, argue later” regime in which the winning party should not be kept out of pocket absent a very strong reason. 

The BLO defendants applied for a stay of execution, which would have required evidence of a good reason so as to deny the judgment creditor the ‘fruits of the judgment’. The BLO defendants, who had the burden of proof, failed to show genuine inability to pay (which is unsurprising given the apparent level of resources available within the wider group).

Importantly, the judgment confirms that BLOs can operate as a powerful enforcement tool for adjudicators’ decisions, extending liability beyond the original contracting party to its associates. In practice, the immediacy of enforcement is not a novel feature of BLOs, but a reflection of adjudication’s established summary enforcement regime, now with a wider net.