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AMICUS AI
Citation Codes
Equivalent Citations
citation codes
Attorney(S)
Acts
  • AAA Construction Industry Arbitration Rules,
  • section 52(4) of the Arbitration Act 1996
  • Arbitration Act 1979.
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Cites
Cited by
Citation Codes
Equivalent Citations
citation codes
Attorney(S)
Acts
  • AAA Construction Industry Arbitration Rules,
  • section 52(4) of the Arbitration Act 1996
  • Arbitration Act 1979.
Smart Summary

Factual and Procedural Background

This case concerns a building contract for the completion of a hotel in the Turks and Caicos Islands. The contract, based on the American Institute of Architects (AIA) standard form, specified that the governing law was that of the place of the project. The arbitration clause provided for arbitration under the American Arbitration Association (AAA) Construction Industry Arbitration Rules, with the arbitration held in Miami, Florida, before a panel of three American arbitrators. The arbitration award was in favor of the contractor, Cavalier Construction Company Limited (Cavalier Bahamas). The owner, The Bay Hotel and Resort Limited (The Bay), unsuccessfully sought to set aside the award in the courts of the Turks and Caicos Islands. The owner appealed to the Privy Council with leave granted by the Court of Appeal, while the contractor cross-appealed on an interest-related point.

The key issues involve whether the arbitration award was a "reasoned" award under the AAA rules, and whether the arbitrators had jurisdiction to add an additional party, Cavalier Construction Company Limited (Turks and Caicos Islands) (Cavalier TCI), to the arbitration and to make an award jointly in its favor. The owner contended that the contractor suffered no loss and thus could not recover damages.

Legal Issues Presented

  1. Whether the arbitration award constituted a "reasoned" award under the AAA Construction Industry Arbitration Rules.
  2. Whether the arbitrators were entitled to add Cavalier TCI as a party to the arbitration against the owner's opposition and make an award jointly with the contractor.
  3. Whether the contractor, Cavalier Bahamas, suffered loss sufficient to recover damages under the contract.
  4. The proper governing law for procedural and substantive issues in the arbitration, including the applicable curial law.

Arguments of the Parties

Appellant's Arguments (The Bay and Zurich)

  • The arbitration award was irregular and improperly procured because Cavalier TCI should not have been joined as a party nor awarded damages.
  • The evidence did not demonstrate that Cavalier Bahamas suffered any loss and therefore it could not recover damages.
  • The award did not provide reasons as required by the scheduling order and natural justice principles.
  • There was alleged error of law apparent on the face of the award.

Respondent's Arguments (Cavalier Companies)

  • The arbitration award was a reasoned award within the meaning of the AAA rules and American arbitration practice.
  • Article 4.9.5 of the contract empowered the arbitrators to join Cavalier TCI as a party to the arbitration.
  • The financial arrangements between Cavalier Bahamas and Cavalier TCI meant that any loss suffered fell on Cavalier Bahamas.
  • The arbitrators properly considered and rejected the no-loss argument.
  • The award and supplemental award should be enforced as a judgment.

Table of Precedents Cited

Precedent Rule or Principle Cited For Application by the Court
Bremer Handelsgesellschaft v Westzucker (No. 2) [1981] 2 Lloyd's Rep 130 Definition of a "reasoned award" requiring explanation of evidence and succinct reasons for decision. The Chief Justice considered but did not accept this definition as applicable under the AAA rules and American law.
James Miller & Partners Ltd. v Whitworth Street Estates (Manchester) Ltd. [1970] AC 583 Distinction between substantive law of contract and procedural or curial law of arbitration. Confirmed that substantive law may differ from procedural law governing arbitration.
Channel Tunnel Group Ltd. v Balfour Beatty Construction Ltd. [1993] AC 334 Multiple national laws may apply in international arbitration; parties consent to arbitration governed by law of seat. Referenced to support discussion on the applicable curial law and seat of arbitration.
Lafarge Redland Aggregates Ltd. v Shephard Hill Civil Engineering Ltd. [2000] 1 WLR 1621 Consent is fundamental to jurisdiction to join parties and consolidate arbitrations. Applied to reject the arbitrators' joinder of Cavalier TCI without consent of The Bay.
Alfred McAlpine Construction Ltd. v Panatown Ltd. [2000] 3 WLR 946 Requirement of loss to recover damages; distinction between contractual parties and beneficiaries. Considered in relation to whether Cavalier Bahamas suffered loss; no basis found to deny recovery.
Phoenican Express SARL v Garware Shipping Corporation Ltd. (QB, 1983) Setting aside awards made in favor of parties not bound by arbitration agreement. Supported severance and setting aside award in favor of Cavalier TCI, a non-party.
UNCITRAL Model Law on International Commercial Arbitration, Article 31(2) Requirement that arbitration awards contain reasons unless parties agree otherwise. Referenced in comparison with English Arbitration Act provisions on reasons for awards.
English Arbitration Act 1996, Section 52(4) and Section 69 Mandates reasons for awards unless agreed otherwise; agreement to dispense with reasons excludes appeal on law grounds. Used to illustrate freedom of parties to agree on the form of award and the scope of reasons required.

Court's Reasoning and Analysis

The court analyzed the governing law and rules applicable to the arbitration, emphasizing the distinction between the substantive law of the contract (Turks and Caicos Islands law) and the procedural or curial law of the arbitration. While the arbitrators and lower courts had treated Miami and United States federal law as the seat and procedural law, the Privy Council held that the agreed law for both substantive and procedural matters was that of the Turks and Caicos Islands, given the contract's express terms.

However, the AAA Construction Industry Arbitration Rules, incorporated into the contract, constituted a self-contained procedural code governing the arbitration, including the form of the award and joinder of parties. The court recognized party autonomy in adopting these institutional rules as the governing code.

Regarding the reasoned award issue, the court noted that the AAA rules equate a "reasoned award" with a "written explanation of the award." Although the award and supplement fell short of what English common law might require for a reasoned award, expert evidence from Professor Carl M. Saper, an experienced American arbitration expert, established that the award complied with the meaning of a reasoned award under American law and the AAA rules. The court accepted this expert evidence, emphasizing that the interpretation must be based on the relevant arbitration code and its professional context, not English legal expectations.

On joinder, the court examined article 4.9.5 of the contract, which restricts consolidation and joinder without consent. The Privy Council concluded this clause was a limitation on jurisdiction rather than an empowering provision. The arbitrators lacked jurisdiction to join Cavalier TCI as a party against The Bay's opposition and to make an award in its favor. The Court of Appeal's attempt to allow joinder without awarding relief was rejected as illogical. Consequently, Cavalier TCI was to be struck out from the award.

Addressing the no loss argument, the court referred to the House of Lords decision in Alfred McAlpine Construction Ltd. v Panatown Ltd., which requires loss for damages recovery. However, the court found no basis to deny Cavalier Bahamas recovery, as there was uncontradicted evidence that Cavalier Bahamas bore the financial loss despite delegating work to Cavalier TCI. The arbitrators' award to Cavalier Bahamas was not flawed by any misconduct or error of law.

On the interest claim, the court declined to interfere with the lower courts' discretion in refusing a late amendment for interest on the award, noting the contractor could pursue separate proceedings for interest.

Holding and Implications

The Privy Council dismissed the appeal by The Bay and Zurich but set aside the joinder of Cavalier TCI as a party to the arbitration and the award made in its favor, leaving intact the award in favor of Cavalier Bahamas and the leave to enforce it as a judgment.

The cross-appeal regarding interest was dismissed without costs. The appellants were ordered to pay the costs of the appeal to Cavalier Bahamas.

The decision confirms that institutional arbitration rules incorporated into contracts govern procedural and jurisdictional issues, including the form of awards and the power to join parties, subject to express consent. It affirms the principle that arbitrations are consensual and that joinder without consent is not permissible. The ruling also clarifies that the meaning of a "reasoned award" depends on the applicable arbitration rules and professional context rather than English common law standards. No new precedent was set beyond the application of existing principles to the facts.

    Bay Hotel and Resort Limited and Zurich Indemnity Company of Canada v. Cavalier Construction Co. Ltd. and Cavalier Construction Co. Ltd (Turks and Caicos Islands)

    1. This case from the Turks and Caicos Islands concerns a building contract

    for the completion of a hotel there. The contract was in a standard form of

    the American Institute of Architects (AIA) and expressly provided that the law

    of the contract was the place of the project. An arbitration clause provided

    for arbitration in accordance with the Construction Industry Arbitration Rules

    of the American Arbitration Association (AAA). An arbitration took place in

    Miami, Florida, being the location requested by both sides, before a panel of

    three American arbitrators selected from a list supplied by the AAA. The

    ultimate award was in favour of the contractor. The owner sought

    unsuccessfully in the courts of the Turks and Caicos Islands to have the award

    set aside. By leave granted by the Court of Appeal, the owner now appeals to

    Her Majesty in Council, while the contractor cross-appeals on a point about

    interest.

    2. The principal issue on the appeal is whether, in the context of this AAA

    arbitration, the award was a "reasoned" one, the trial judge having accepted

    the evidence of an American expert witness that it did answer that description.

    Another issue is whether the arbitrators were entitled, as they did, to add an

    additional party to the arbitration on the request of the contractor and

    against the opposition of the owner; and to make an award to the additional

    party jointly with the contractor. This issue is linked with a contention on

    the part of the owner that the contractor itself has suffered no loss and

    therefore cannot recover damages.

    3. The foregoing are the basic facts and issues. Before returning directly to

    them their Lordships will state in more detail, in paragraphs 4 to 32 of this

    judgment, the history and circumstances of the case, and the manner in which it

    has been dealt with in the courts below.

    Background

    4. The Crown Bay Resort Hotel, Providenciales, had been partly constructed. A

    bondsman, Zurich Indemnity Company of Canada (Zurich), having been called upon

    under its bond, elected to complete the work, expecting that the cost of doing

    so would be less than the full amount of the bond. Zurich formed a company in

    the Turks and Caicos Islands, The Bay Hotel and Resort Limited (The Bay), to be

    the employer of the contractor chosen to complete the hotel, an established

    construction company registered in The Bahamas called Cavalier Construction

    Company Limited (Cavalier Bahamas). The Bay as owner and Cavalier Bahamas as

    contractor entered into an elaborate construction contract dated 18th August

    1993. On the same date Zurich, in writing, guaranteed payment to Cavalier

    Bahamas of sums due to the contractor under that contract. The guarantee was

    limited to US$17 million.

    5. The contract, in which an address in Ontario is given as the address of The

    Bay, was in the form (with amendments) of the 1987 edition of AIA document

    A111, Standard Form of Agreement between Owner and Contractor. There was a

    maximum price of US$15,625,000.00; it has not been argued that this limits

    recoverable damages. By article 13.1.1 the contract is to be governed by the

    law of the place where the project is located. Article 4.9.1 provides, so far

    as relevant -

    "Any controversy or Claim arising out of or related to the Contract, or the

    breach thereof, shall be settled by arbitration in accordance with the

    Construction Industry Arbitration Rules of the American Arbitration

    Association, and a judgment upon the award rendered by the arbitrator or

    arbitrators may be entered in any court having jurisdiction thereof, ..."

    Similarly a contractual document following the instruction sheet includes "Is

    arbitration the desired method of dispute resolution? Is arbitration recognised

    as a valid method of dispute resolution by the laws of the Turks and Caicos

    Islands? Disputes shall be resolved according to the laws of Turks and Caicos

    Islands". The last words "Turks and Caicos Islands" were added in writing.

    (The reference is A1A 201 CMa-1992; entry opposite G paragraph 4.6.)

    6. The applicable rules are the Construction Industry Arbitration Rules of the

    AAA, revised and in effect on 1st April 1996. The AAA offers "Dispute

    Resolution Services Worldwide". The rules include provisions for "Large,

    Complex Case Track" procedures which apply to this case. As to the form of the

    award, rule 42, which is part of the regular track rules but is not excluded by

    the special procedures, reads as follows -

    "R. 42. FORM OF AWARD

    The award shall be in writing and shall be signed by a majority of the

    arbitrators. It shall be executed in the manner required by law. The

    arbitrator shall provide a concise, written breakdown of the award. If

    requested in writing by all parties prior to the appointment of the arbitrator,

    or if the arbitrator believes it is appropriate to do so, the arbitrator shall

    provide a written explanation of the award."

    Under R.41 the award is to be made, unless otherwise agreed, within 30 days of

    the closing of the hearing.

    7. By R.11 the parties may mutually agree on the locale where the arbitration

    is to be held. If one party objects to the locale requested by the other, the

    AAA has power to determine the locale. As for procedure and the lex

    arbitri generally, the rules contain some provisions recognising that there

    may be an applicable law (e.g. R.42 above, and R.25 whereunder the arbitrator

    shall maintain the privacy of the hearings "unless the law provides to the

    contrary") but are silent as to what system of law may govern the conduct of

    the arbitration. Their scheme is, rather, that they constitute a

    self-contained code on which a national law may impinge or operate as an

    aid.

    8. The concept of a self-contained code is also apparent from R.53 -

    "R.53. INTERPRETATION AND APPLICATION OF RULES

    The arbitrator shall interpret and apply these rules insofar as they relate to

    the arbitrator's powers and duties. When there is more than one arbitrator and

    a difference arises among them concerning the meaning or application of these

    rules, it shall be decided by a majority vote. If that is not possible, either

    an arbitrator or a party may refer the question to the AAA for final decision.

    All other rules shall be interpreted and applied by the AAA."

    9. The contractor's work under the contract was in fact carried out by a

    company formed by Cavalier Bahamas in the Turks and Caicos Islands. It bears

    the same name, Cavalier Construction Company Limited, as Cavalier Bahamas and

    is conveniently referred to as Cavalier TCI. According to The Bay, the

    existence of Cavalier TCI and the fact that it had done the work were not known

    to The Bay until discovery of documents in the arbitration shortly before the

    hearing commenced. As to the relationship between the two Cavalier companies

    the trial judge, Ground CJ, made the following important findings -

    "Mr. Wilson, the Managing Director of Cavalier Bahamas, explained in his

    evidence in chief that, although the Construction Contract was with Cavalier

    Bahamas, a separate company was set up to perform the work. This was Cavalier

    TCI. He explained that this approach was dictated by currency and other

    considerations of operating in what was, for him, a foreign jurisdiction. He

    said that Cavalier TCI was entirely funded by the parent company, who also

    provided plant, equipment and management. All net profits of Cavalier TCI

    company were to be remitted to the Bahamas (although it is not said to the

    Bahamian parent) as were all dividends. Mr. Wilson asserts that Cavalier TCI

    was never considered to be any more than an extension of the parent, who

    financed it in its entirety. None of that is seriously challenged on the

    evidence before me, and find it to be true."

    10. The Chief Justice went on to comment -

    "Against that background , it was part of the Bay's case at the arbitration

    that as all the work on the project had been performed, and all the financial

    liabilities incurred by Cavalier TCI, there was no evidence of loss on the part

    of Cavalier Bahamas. It was therefore argued that the claimants' case in the

    arbitration must necessarily fail. Whatever the legal force of that argument,

    it sat ill in the mouth of a party who was counterclaiming against Cavalier

    Bahamas for delay and defects in the performance of the construction contract,

    and was not likely to be one to appeal to a panel of construction

    arbitrators."

    Mr Wilson and the Nassau attorney who had been involved in obtaining permission

    from The Bahamas Central Bank to form Cavalier TCI had apparently given similar

    evidence to the arbitrators.

    11. Work under the contract was late. There were also disputes about the

    quality of the work. In May 1996 Cavalier Bahamas demanded arbitration under

    the AAA Rules, claiming US$5,632,311.00 and naming The Bay as respondent. The

    Bay lodged with the AAA an answering statement, noting that Cavalier Bahamas

    was claiming both for work under the contract and for delay damages; denying

    liability; and counterclaiming for rectification expenditure and delay damages

    US$6,819,303.00.

    12. A preliminary hearing took place before the arbitrators in Miami on 14th

    August 1996. At that stage counsel for Cavalier Bahamas were Bahamian lawyers;

    counsel for The Bay were Canadian lawyers. The latter continued to represent

    The Bay throughout the arbitration; at the substantive hearing of the

    arbitration a Washington DC attorney, Mr. McManus, appeared as leading counsel

    for Cavalier Bahamas. By agreement of the parties and by order of the

    arbitrators, various procedural directions were given at the preliminary

    hearing, as recorded in a report of preliminary hearing and scheduling order

    signed by the arbitrators and sent to the AAA. Item 7 provided "The form of

    the award in this proceeding shall be a Reasoned Award".

    13. That reference to a "Reasoned Award" reflected the terms of a pro forma

    instruction form or check list issued by the AAA, which in paragraph 9 as to

    the form of the award indicated that one of the following should be circled:

    (1) Standard award; (2) Reasoned award; (3) Findings of fact and conclusions of

    law. As has been seen, such a threefold choice did not mirror AAA R.42

    whereunder the alternatives were a concise written breakdown of the award and a

    written explanation of the award. But it has become common ground, accepted in

    the present court proceedings by the expert witnesses on each side and by the

    Turks and Caicos courts also, that a reasoned award and a written explanation

    of the award are expressions with the same meaning. So nothing turns on this

    difference of language.

    14. Pleadings and discovery was exchanged by the parties in the arbitration.

    At that stage Cavalier Bahamas claimed some US$8.65 million. By counterclaim

    The Bay sought some US$3.1 million. The hearing was conducted in Miami, with

    an incidental visit to the site, between 14th July and 10th October 1997.

    During the hearing The Bay raised the no loss point. At the end of the

    claimant's case Cavalier Bahamas, pursuant to a notice of motion dated 30th

    July 1997, sought leave to add Cavalier TCI as a party as both claimant and

    respondent. The grounds given were that The Bay had alleged that the real

    party in interest in the dispute was Cavalier TCI: while the claimant disputed

    that allegation, both the claimant and Cavalier TCI sought the joinder to cure

    any potential prejudice to The Bay. Thus the application was clearly no more

    than precautionary. The Bay opposed the application and has consistently

    maintained that the arbitrators had no jurisdiction to grant it. Nevertheless

    the arbitrators did grant it, thus occasioning one of the main issues in the

    subsequent litigation.

    15. The motion to add Cavalier TCI in the arbitration disclaimed reliance on

    any specific AAA rule, saying "There being no Rule of the American Arbitration

    Association governing this Motion, the panel may permit this Motion to Amend

    the Pleadings within its sound discretion". It was contended in the courts

    below, however, and has been contended again before their Lordships, that

    jurisdiction could be extracted from article 4.9.5 in the general conditions

    incorporated in the contract -

    "Limitation on consolidation or Joinder.

    No arbitration arising out of or relating to the Contract Documents shall

    include, by consolidation or joinder or in any other manner, the Construction

    Manager, the Architect, or the Construction Manager's or Architect's employees

    or consultants, except by written consent containing specific reference to the

    Agreement and signed by the Construction Manager, Architect, Owner, Contractor

    and any other person or entity sought to be joined. No arbitration shall

    include, by consolidation or joinder or in any other manner, parties other than

    the Owner, Contractor, other Contractors as described in Article 6 and other

    persons substantially involved in a common question of fact or law whose

    presence is required if complete relief is to be accorded in arbitration. No

    persons or entities other than the Owner, Contractor, other Contractors as

    defined in Subparagraph 3.1.2 shall be included as an original third party or

    additional third party to an arbitration whose interest or responsibility is

    insubstantial. Consent to arbitration involving an additional person or entity

    shall not constitute consent to arbitration of a dispute not described therein

    or with a person or entity not named or described therein. The foregoing

    agreement to arbitrate and other agreements to arbitrate with an additional

    person or entity duly consented to by parties to the Agreement shall be

    specifically enforceable under applicable law in any court having jurisdiction

    thereof."

    The arbitrators were not asked to give and did not give formally their reasons

    for granting the joinder.

    16. The award of the arbitrators, dated 7th November 1997 reads as follows

    -

    "We, the undersigned arbitrators having been designated in accordance with the

    Arbitration Agreement entered into by the above named parties and having been

    duly sworn and having duly heard the proofs and allegations of the parties,

    hereby award as follows:

    1. The Motion of the Claimant, CAVALIER CONSTRUCTION COMPANY, LTD. to amend the

    pleadings herein to add CAVALIER CONSTRUCTION COMPANY, LTD., a Turks and Caicos

    Company, as a party to these proceedings is hereby granted. Accordingly, the

    award herein, as it pertains to CAVALIER CONSTRUCTION COMPANY, LTD., shall

    pertain to CAVALIER CONSTRUCTION COMPANY, LTD., a Bahamas corporation and

    CAVALIER CONSTRUCTION COMPANY, LTD., a Turks and Caicos Company, jointly and

    severally.

    2. Claimant, CAVALIER CONSTRUCTION COMPANY, LTD.'s Motion to Add Zurich

    Indemnity Company of Canada as an additional respondent in these proceedings is

    hereby denied without prejudice as to the merits of any claim which Claimant

    may have against Zurich Indemnity Company of Canada and without prejudice to

    Claimant's right to pursue any such claim in any other forum.

    3. Upon consideration of the claims and counterclaims of each of the parties

    against the other asserted herein, including Claimant's revised claim of

    $8,348,941.00 and Respondent's revised Counterclaim of $2,678,100.39, the

    Arbitrators award Claimant, the net sum of $4,027,205.00; therefore,

    Respondent, THE BAY HOTEL AND RESORT, LTD., shall pay Claimant, CAVALIER

    CONSTRUCTION COMPANY, LTD., the sum of Four Million Twenty Seven Thousand Two

    Hundred Five Dollars, United States currency ($4,027,205.00).

    4. Of the foregoing sum awarded Claimant, but not in addition thereto, the sum

    of $280,090.00 is allocated to Claimant's subcontractor, John J. Karlin, Inc.

    and the sum of $148,270.00 is allocated to Claimant's subcontractor, AG

    Electric Co. Ltd.

    5. By agreement of the parties the Arbitrators will separately consider the

    award of costs and attorneys' fees in accordance with the Protocol With Respect

    to Costs executed and submitted by the parties and shall thereafter issue a

    supplemental award with respect thereto."

    17. The Bay did not accept that this was a reasoned award as required by the

    report of preliminary hearing scheduling order, item 7, and requested the AAA

    that the arbitration panel provide such an award. In the result the

    arbitrators issued a supplement to their award dated 25th November 1997,

    reading in full -

    "We the undersigned arbitrators, upon consideration of the request the

    Respondent for a more detailed reasoned award in this matter, issue this

    Supplement to the Award of the Arbitrators herein dated November 7, 1997:

    1. The Arbitrators hereby reaffirm the Award of the Arbitrators dated November

    7, 1997 in all respects.

    2. The matters set forth in Paragraphs 1, 2, 4 and 5 of the Award of November

    7, 1997 are self-evident and warrant no further comment.

    3. Paragraph 3 of the Award of November 7, 1997 is hereby supplemented as

    follows:

    a. On the basis of the testimony and evidence of the parties, the Arbitrators

    find that Respondent breached the Agreement Between Owner and Contractor (the

    `Contract') between The Bay Hotel and Resort, Ltd. (hereinafter `THE BAY'), as

    Owner, and Cavalier Construction Company, Ltd. (`CAVALIER'), as Contractor,

    dated August 18, 1993, for construction of the Crown Bay Resort Hotel by

    unreasonably interfering with and delaying CAVALIER's performance under the

    Contract, by requiring CAVALIER to perform work beyond the scope of the

    Contract without compensation, and by failing to make payments as required.

    b. On the basis of the testimony and evidence of the parties, the Arbitrators

    find that the sum of $619,l88.00, the Contract balance as adjusted through

    Change order No. 8, is due CAVALIER.

    c. On the basis of the testimony and evidence of the parties, the Arbitrators

    find that CAVALIER is entitled to an adjustment of the Contract in the sum of

    $4,566.00 for mutual mistake; more specifically, a mathematical computation

    error in Attachment `A' to the Contract.

    d. On the basis of the testimony and evidence of the parties, the Arbitrators

    find that CAVALIER is entitled to no further adjustment for Contractor's Fee

    for work deleted from the Contract pursuant to Change Orders executed without a

    reservation of rights.

    e. On the basis of the testimony and evidence of the parties, however, the

    Arbitrators find that CAVALIER is entitled to $59,515.00 for the Contractor's

    Fee portion of work deleted from the Contract by THE BAY where CAVALIER's

    rights with respect to such Fee were reserved.

    f. On the basis of the testimony and evidence of the parties, the Arbitrators

    find that CAVALIER is entitled to $536,038.00 for changes and additions to the

    Work under the Contract not compensated under executed Change Orders.

    g. On the basis of the testimony and evidence of the parties, the Arbitrators

    find that THE BAY is entitled to $85,112.00 for incomplete and/or defective

    work claimed in its schedules A, B, C and D, of which the sun of $17,147.00 is

    attributed to the work of John J. Kirlin, Inc. and $924.00 is

    attributed to the work of AG Electric Co. Ltd.

    h. On the basis of the testimony and evidence of the parties, the Arbitrators

    find that CAVALIER is entitled to $544,381.00 for remedial work performed

    beyond the scope of the Contract.

    i. On the basis of the testimony and evidence of the parties, the Arbitrators

    find that CAVALIER is entitled to damages for delay and disruption in the

    amount of $1,516,605.00.

    j. On the basis at the testimony and evidence of the parties, the Arbitrators

    find that CAVALIER is entitled to interest in the amount of $385,590.00 for its

    own account, interest in the amount of $30,009.00 for the benefit of John J.

    Kirlin, Inc. and interest in the amount of $15,886.00 for the benefit of AG

    Electric Co. Inc.

    k. On the basis of the testimony and evidence of the parties, the

    Arbitrators find that the Guaranteed Maximum Price of the Contract should be

    adjusted for all of the items set forth herein and CAVALIER's reimbursable cost

    of the Work under the Contract exceeds the adjusted Guaranteed Maximum Price of

    the Contract.

    4. The remaining requested findings of CAVALIER and THE BAY are not supported

    by the testimony and evidence of the parties and are therefore denied by the

    Arbitrators."

    18. Pursuant to a protocol that had been agreed between the parties, the

    arbitrators made a supplemental award, dated 1st December 1997, with respect to

    costs and fees. It was in favour of the contractor.

    19. Various proceedings not now calling for particularisation were brought

    abortively by one or other of the parties in the courts of Ontario, the Turks

    and Caicos Islands and Florida. On 3rd December 1997 The Bay as first

    plaintiff and Zurich as second plaintiff commenced in the Supreme Court of the

    Turks and Caicos Islands the action out of which the present appeal arises.

    Zurich has as such taken no active part in the proceedings; separate

    consideration of its position is not required. Cavalier Bahamas was named as

    first defendant, Cavalier TCI as second defendant. The action came to trial on

    re-amended pleadings. The Bay and Zurich claimed a declaration that the award

    delivered on 7th November 1997 was improperly procured within the meaning of

    section 16(2) of the Arbitration Ordinance of the Turks and Caicos Islands; and

    a declaration and order that it be set aside. The Cavalier companies

    counterclaimed for declarations and orders that the award and the costs award

    be enforced with leave of the court in the same manner as a judgment to that

    effect.

    20. So far as they have survived to the Privy Council, the grounds of the

    claims of The Bay and Zurich are in summary that the award was irregular and

    improperly procured in that Cavalier TCI should not have been joined, nor

    should any award have been made in its favour; that the evidence before the

    arbitrators did not demonstrate any loss suffered by Cavalier Bahamas; and that

    the award did not give reasons, contrary to the scheduling order and the rules

    of natural justice. Apart from invocation of section 16(2) of the Arbitration

    Ordinance, there is also alleged to be error of law on the face of the

    award.

    21. In the Turks and Caicos Islands the Arbitration Ordinance (Chapter 47,

    Ordinance 7 of 1974, as amended) is not in the form of a comprehensive code but

    contains limited and miscellaneous provisions about arbitration, apparently

    largely derived from English legislation before the Arbitration Act 1979. As

    regards references by consent out of court, there is no provision for appeal to

    the courts on questions of law or for remission of awards to arbitrators.

    Section 16 reads -

    "16.(1) Where an arbitrator, umpire or referee has misconducted himself, the

    court may remove him.

    (2) Where an arbitrator, umpire or referee has misconducted himself, or the

    arbitration award or report has been improperly procured, the court may set

    aside the award or report."

    Section 18 provides that any arbitrator or referee may at any stage of the

    proceedings under a reference, and shall if so directed by the court, state in

    the form of a special case for the opinion of the court any question of law

    arising in the course of the reference. No party sought to invoke this

    procedure in the present arbitration. Section 4 and paragraph 8 of the

    Schedule make the award, unless set aside under section 16(2), final and

    binding on the parties and the persons claiming under them.

    22. As to the counterclaim, section 10 of the Ordinance provides that any

    award on a submission may, by leave of the court, be enforced in the same

    manner as a judgment or order to the same effect. Article 4.9.7 of the instant

    construction contract contains a corresponding provision, which it is

    unnecessary to set out.

    The judgments in the Turks and Caicos Islands

    23. In his judgment, delivered on 26th March 1999, Ground CJ dealt first with

    the questions relating to joinder. He considered that article 4.9.5 of the

    general conditions was the only possible source of jurisdiction in the

    arbitrators to join Cavalier TCI, and that the construction of the article was

    a question of Turks and Caicos Islands law: this was, he said, a matter for him

    on the wording of the document itself. He accepted that, if joinder was

    permissible, he should not inquire into whether it was appropriate or not in

    the circumstances of the case. He went on to hold that joinder was

    permissible. Saying that the true construction of the paragraph was obscured

    by the order of its components and the way in which it was cast in the

    negative, he re-ordered it and in some respects rewrote it. In this process he

    fastened on the words "and other persons substantially involved in a common

    question of fact or law whose presence is required if complete relief is to be

    awarded in arbitration". These words he saw in their context as constituting an

    agreement to arbitrate with such persons; so that The Bay could be compelled,

    without its consent and notwithstanding its objection, to arbitrate with

    Cavalier TCI provided that the latter company consented.

    24. On the issue concerning reasons the Chief Justice found that under R.42

    the arbitrators were required to provide no more than a concise written

    breakdown of the award. The scheduling order was not capable of overriding

    that, for in terms of the rule it did not constitute a request by the parties

    prior to the appointment of the arbitrator. Nor was the obligation of the

    arbitrators increased by anything said or done at later stages of the

    arbitration when discussions occurred and submissions were made about the form

    of the award. And in his view the award of 7th November 1997, as supplemented

    on request by the document of 25th November 1997, did provide a concise written

    breakdown sufficient to satisfy R.42.

    25. In case he was wrong in that view, Ground CJ went on to consider whether

    the award, so supplemented, was a reasoned award. He accepted that a reasoned

    award and a written explanation of the award within the meaning of the rule

    were the same thing. The Bay and Zurich had relied on a proposition of

    Donaldson LJ in Bremer Handelsgellschaft v Westzucker (No. 2) [1981] 2

    Lloyd's Rep 130, 132-133 -

    "All that is necessary is that the arbitrators should set out what, on their

    view of the evidence, did or did not happen and should explain succinctly why,

    in the light of what happened, they have reached their decision and what that

    decision is. That is all that is meant by a `reasoned award'."

    Ground CJ did not accept the applicability of that proposition, because he

    concluded that, under English and therefore Turks and Caicos Islands law, there

    is a strong prima facie presumption that the law to be applied to the

    procedure of an arbitration is that of the place where the arbitration has its

    seat. Here he found that the agreed seat of the arbitration was Miami. He

    thought that the Federal Arbitration Act rather than Florida state law applied,

    but that this made no practical difference as the evidence was that the meaning

    of reasoned award had not been determined by any American court, state or

    federal. He found, however, on considering the expert evidence that the award

    was a reasoned award as that term is understood in the United States of

    America.

    26. That finding is of critical importance in the case. It was based

    essentially on the evidence of Professor Carl M. Saper, who holds a chair at

    Harvard University and has had very extensive practical experience in the field

    of arbitration. So far as there was any dispute between the expert witnesses,

    Ground CJ said that he much preferred Professor Saper's analysis and expertise

    to that of the expert called on the other side (The Bay and Zurich). What was

    American law was a question of fact, and the Chief Justice said -

    "As I said above, I accept Professor Saper's evidence. Indeed I found him a

    compelling witness, because of his experience in the field, his academic

    and other credentials (all of which are set out in his witness statement and

    which I need not rehearse), and because of what I consider to be the logical

    integrity of his arguments. It was his opinion that the Award when taken with

    its supplement constituted a reasoned award.

    It was also his evidence that there was no necessity to tell the loser why he

    lost, and that that was not the purpose of a reasoned award. He did not accept

    Donaldson LJ's formulation as a definition of a `reasoned award,' and did not

    accept it was necessary to go through each schedule of loss separately as they

    all fell into well known categories of issues and could be disposed of as one.

    Moreover, he did not consider it was necessary for an arbitrator to go through

    such schedules item by item. Indeed be felt that that would be very rare in

    the case of a reasoned award, and not typical. He accepted that the actual

    Award (taken with the supplement) was a `lean award,' which could have had a

    `richer embellishment', but he said such an award was quite typical in the

    United States and would not be subject to rebuke or vacation.

    I consider that that last observation by Professor Saper holds the key to much

    of what is in dispute between the parties. Practices and procedures in the

    United States may have an apparent familiarity to English lawyers, which on

    closer examination proves to be deceptive. Similarly, procedural terminology

    may seem similar and mean different things. The different approach to

    discovery between the two jurisdictions is but one example of this. The

    defendants say that the plaintiffs' problem is that they have strayed into a

    difficult legal system which they are trying to make conform to their own. The

    plaintiffs say that this is a `through the looking glass' argument. At the end

    of the day, on the evidence, I prefer the defendants' approach, and if it turns

    out that the evidence of their expert leads to a different result from that

    which would have obtained if English law had applied, and which seems wrong to

    English trained eyes, that is not of itself a ground for rejecting it."

    27. Three other points remain to be mentioned briefly regarding the judgment

    at first instance. The Chief Justice disposed of the natural justice argument

    on the simple basis that the parties to an arbitration get what they have

    contracted for - a view which has not subsequently been challenged. He gave

    leave to the Cavalier companies to enforce the award in the same manner as a

    judgment to the same effect. Last he declined a belated application for leave

    to amend the counterclaim to include a claim for interest on the amount awarded

    from the date of the award (or some subsequent date) until the date of

    judgment. He said inter alia that whether the award carried interest

    depended on the terms of the contract and had not been in issue before him

    during the trial of the action.

    28. In the Court of Appeal of the Turks and Caicos Islands the case came

    before Sir James Astwood P and Campbell and Kerr JJA. The judgment of the

    court was delivered on 9th February 2000 by Kerr JA. After citing the

    well-known passage in the speech of Lord Mustill in Channel Tunnel Group Ltd

    . v Balfour Beatty Construction Ltd. [1993] AC 334, 357-358, as to how more

    than one national system of law may bear upon an international arbitration, and

    also the judgment of Kerr LJ in Naviera Amazonica Peruana S.A. v Compania

    Internacional De Seguros Del Peru [1988] 1 Lloyd's Rep 116, 119, the Court

    of Appeal upheld the conclusion of Ground CJ that the procedural law in this

    case was the Federal Act of the United States.

    29. The Court of Appeal then turned to the question of joinder. Again they

    upheld the Chief Justice - but with a major qualification later in their

    judgment, which will be mentioned again shortly. Their reasoning for accepting

    a power of joinder was somewhat simpler than that of the Chief Justice. They

    did not engage in any notional rewriting of article 4.9.5 of the general

    conditions of contract. Rather they attached importance to the omission of any

    reference to consent, an omission which they regarded as purposeful and

    contrasting, in the sentence -

    "No arbitration shall include, by consolidation or joinder or in any other

    manner, parties other than the Owner, Contractor, other Contractors as

    described in Article 6 and other persons substantially involved in a common

    question of fact or law whose presence is required if complete relief is to be

    accorded in arbitration."

    The Court of Appeal thought that the satisfaction of these criteria was a

    matter of fact for the arbitrators and was independent of any consent by the

    parties.

    30. Next the Court of Appeal dealt with the reasoned award issue. They said

    that it was accepted by counsel for The Bay and Zurich that the Ordinance did

    not impose any obligation to provide a reasoned award; any obligation arose

    from the AAA rules and the arbitration agreement. That view of the matter has

    again not been challenged before their Lordships . As to the effect of the

    rules and the agreement, the Court of Appeal held that the Chief Justice had

    been entitled to accept the evidence of Professor Saper "which would be useful

    for its dictionary effect and as to the meaning of `Reasoned Award' in the

    profession of Architects and the expectations of those who use this AAA form of

    contract".

    31. Having affirmed the Chief Justice thus far, the Court of Appeal, in the

    judgment delivered by Kerr JA, then dealt with a point which they said had not

    been raised before the arbitrators, nor specifically in the court below.

    Referring to an unreported judgment of Hobhouse J in the Queen's Bench Division

    in 1993, they held that Cavalier TCI, although in their view properly joined,

    had not properly been made a joint awardee. Accordingly the Chief Justice's

    leave for enforcement could not stand insofar as it related to Cavalier TCI.

    As they put it, it is beyond dispute that Cavalier Bahamas as the other party

    to the construction contract had the burden of the obligations and was entitled

    to the benefits under the contract. To make Cavalier TCI an awardee would

    confer through arbitration proceedings benefits arising from a contract to

    which that company was not a party. Accordingly the appeal was allowed to the

    limited extent of amending the award by deleting Cavalier TCI as a party in

    favour of whom it was made. It is convenient to interpolate that their

    Lordships see no reason why such an amendment should not be made if an award is

    clearly severable.

    32. The Court of Appeal dismissed a cross-appeal as to interest, saying that

    no reasonable ground for the requested amendment had been offered either to the

    Chief Justice or to the Court of Appeal.

    The Governing Code

    33. Their Lordships turn to consider the main issues in the case. As already

    explained, they are whether there was a reasoned award and whether Cavalier was

    properly joined in the arbitration (this being linked with the no loss point).

    To determine these issues, in part procedural and in part jurisdictional, it is

    necessary to decide what system of law or what rules govern the questions.

    34. In English law, and therefore in Turks and Caicos law, it has been settled

    since at least James Miller & Partners Ltd. v Whitworth Street Estates

    (Manchester) Ltd. [1970] AC 583 that the proper or substantive law of a

    contract may differ from the procedural or curial law of an arbitration

    thereunder. In that case there was a difference of opinion in the House of

    Lords as to the proper law of a construction contract made in a standard

    R.I.B.A. form. Lord Hodson, Lord Guest and Viscount Dilhorne held that the

    proper law was that of England. Lord Reid and Lord Wilberforce preferred the

    view that it was Scottish law. But all five members of the House held that the

    curial law was that of Scotland, where the project was situated and the

    arbitration took place. Hence the (Scottish) arbiter could not be required to

    state a case for the opinion of the English High Court.

    35. Two points in the speech of Lord Wilberforce are notable here. First, he

    said that in the normal case where the contract itself is governed by English

    law, any arbitration would be held under English procedure. Secondly, he said

    that the mere fact that the arbitrator was to sit either partly or exclusively

    in another part of the United Kingdom, or, for that matter, abroad, would not

    lead to a different result: the place might be chosen for many reasons of

    convenience or be purely accidental; a choice so made should not affect the

    parties' rights. The passage in his speech is at page 616 of the report.

    36. Especially because of the extent to which it was relied on in this case by

    the courts of the Turks and Caicos Islands, reference is also appropriate to

    the speech of Lord Mustill, agreed with by the other members of the House, in

    Channel Tunnel Group Ltd. v Balfour Beatty Construction Ltd., cited

    earlier. In that case the proper law of the contract was contractually defined

    as "the principles common to both English law and French law, and in the

    absence of such common principles, by such general principles of international

    trade law as have been applied by national and international tribunals". The

    arbitration clause explicitly provided "The seat of such arbitration shall be

    Brussels". In that context it is not surprising that Lord Mustill, in the

    passage cited in the Turks and Caicos Islands (see [1993] AC at 357-358), found

    it irresistible that the parties when contracting to arbitrate in a particular

    place consented to having the arbitral process governed by the law of that

    place.

    37. In the present case the parties did not agree in the construction contract

    that Miami should be the seat of any arbitration. When the need for

    arbitration arose they severally requested the hearing to be in Miami for

    convenience. The courts should not be astute to hold that the curial law of an

    arbitration is different from the proper law of the contract (see the

    observations of Lord Wilberforce already quoted); and it is doubtful whether,

    in the absence of some other weighty factor, the requests of the parties for a

    Miami hearing would have been enough to justify such a conclusion. As it is,

    however, there is an overriding factor. This is the addition to the contract

    of an agreed term that disputes shall be resolved according to the laws of

    Turks and Caicos Islands. It amounts to an express choice of the same curial

    law as the proper law, the latter having already been defined in article 13.1.1

    of the general conditions of the contract as the law of the place where the

    project was located. The Board is therefore unable to uphold the view of the

    courts of the Turks and Caicos Islands that the agreed seat of the arbitration

    was Miami and the applicable procedural law the federal law of the United

    States. For both substance and procedure the relevant national law is that of

    the Turks and Caicos Islands.

    38. But identifying the national curial law of the arbitration is not

    important in the resolution of the present case. The reason has already been

    indicated. The AAA Construction Industry Arbitration Rules, incorporated in

    the construction contract, constitute a code which provides answers to both the

    reasoned award issue and the joinder issue. When contracts specify arbitration

    under the rules of a particular institution such as the AAA, it is not uncommon

    that procedural and jurisdictional issues are governed by those rules. A

    national law may be in the background. It may have an invalidating effect or

    an auxiliary role. In the present appeal no problem arises under either of

    those heads. If the award complied with the AAA rules, there can be no doubt

    that the Supreme Court could give leave to enforce it. Such qualifications

    aside, the adoption by the parties of an institutional code enables issues to

    be resolved by application of that code. This is a consequence of party

    autonomy, which, although spoken of rather disparagingly by one of the counsel

    who argued before the Board, is generally accepted as a key principle of

    current arbitration law. In other words, the law of the Turks and Caicos

    Islands entitled the parties to select the AAA code, so far as it might cover

    issues arising in an arbitration, to govern the determination of their

    disputes.

    The Reasons Issue

    39. It being common ground that under the AAA code "a reasoned award" and "a

    written explanation of the award" are synonymous, the main issue is whether the

    award and the supplemental award, read together, answer that description for

    the purposes of that code.

    40. In current English law, section 52(4) of the Arbitration Act 1996 provides

    that the award shall contain the reasons for the award unless it is an agreed

    award or the parties have agreed to dispense with reasons. Article 31(2) of

    the UNCITRAL Model Law on International Commercial Arbitration makes similar

    provision. In recommending the provision that became section 52(4) of the

    English Act, the Departmental Advisory Committee on Arbitration Law, chaired by

    Lord Justice Saville, said in paragraph 247 of their Report of February 1996

    -

    "247. To our minds, it is a basic rule of justice that those charged with

    making a binding decision affecting the rights and obligations of others should

    (unless those others agree) explain the reasons for making that decision. This

    was also the view of the majority of those who commented on this."

    41. It is to be noted, however, that this basic rule is seen as subject to the

    contrary agreement of the parties. Consistently, section 69 of the English Act

    of 1996, which enables in strictly defined circumstances appeals to the court

    on questions of law, stipulates in subsection (1) that an agreement to dispense

    with reasons for the tribunal's award shall be considered an agreement to

    exclude the court's jurisdiction under this section. There can be no doubt

    that at common law the parties are free to agree on a form of award which would

    constitute something less than a reasoned award in the eyes of English common

    lawyers. Nor does the Arbitration Ordinance of the Turks and Caicos Islands

    contain anything to restrict that freedom.

    42. No doubt, to anyone familiar with the issues in the arbitration the award

    and the supplemental award would convey more about the reasons of the tribunal

    than would be apparent to an outsider. Even so, their Lordships accept that

    the documents fall short of what English common lawyers would regard as a

    reasoned award. The criteria stated by Donaldson LJ (see paragraph 25 above)

    would not be satisfied. Nor would the superficially attractive but perhaps

    simplistic test that the loser should be told not only that he has lost but

    also why he has lost.

    43. Nonetheless, the question is not what English common lawyers would say.

    It is what reasoned award or written explanation of the award would mean to

    persons versed in working with the AAA code. This is a question of fact,

    analogous to a question of trade usage or custom. Ground CJ found Professor

    Saper's evidence upon it impressive and conclusive. The Court of Appeal

    affirmed the Chief Justice; they justifiably treated his evidence as not

    discriminating on this question of interpretation between American law

    generally and the AAA rules. Their Lordships could not rightly differ. However

    lean and unembellished, the award with its supplement must be found to have

    been reasoned within the meaning of the institutional rules. It is not without

    relevance, albeit not decisive, to add that counsel for The Bay accepted in the

    Privy Council that, if the arbitration had been governed by United States law,

    the award and supplement would have to be treated as a reasoned award. Whether

    or not the curial law of the arbitration, United States law is a major aid in

    interpreting the AAA rules. And it would be unconvincing to propose that,

    when those rules apply, the meaning for their purpose of "a written explanation

    of the award" or "a reasoned award" will vary according to where the

    arbitration is held. The main attack upon the award must fail.

    The Joinder Issue

    44. For the common law position as to joinder in England and the Turks and

    Caicos Islands, it is useful to reproduce some paragraphs in the 1996 Report of

    the Department Advisory Committee previously mentioned. Headed "Clause 35

    Consolidation of Proceedings and Concurrent Hearings", they read -

    "177. This Clause makes clear that the parties may agree to consolidate their

    arbitration with other arbitral proceedings or to hold concurrent

    hearings.

    178. During the consultation exercises, the DAC received submissions calling

    for a provision that would empower either a tribunal or the Court (or indeed

    both) to order consolidation or concurrent hearings. These were considered

    extremely carefully by the committee.

    179. The problem arises in cases where a number of parties are involved. For

    example, in a construction project a main contractor may make a number of

    sub-contracts each of which contains an arbitration clause. A dispute arises

    in which a claim is made against one sub-contractor who seeks to blame another.

    In Court, of course, there is power to order consolidation or concurrent

    hearings, as well as procedures for allowing additional parties to be joined.

    In arbitrations, however, this power does not exist. The reason it does not

    exist is that this form of dispute resolution depends on the agreement of the

    contracting parties that their disputes will be arbitrated by a private

    tribunal, not litigated in the public courts. It follows that unless the

    parties otherwise agree, only their own disputes arising out of their own

    agreement can be referred to that agreed tribunal.

    180. In our view it would amount to a negation of the principle of party

    autonomy to give the tribunal or the Court power to order consolidation or

    concurrent hearings. Indeed it would to our minds go far towards frustrating

    the agreement of the parties to have their own tribunal for their own disputes.

    Further difficulties could well arise, such as the disclosure of documents from

    one arbitration to another. Accordingly we would be opposed to giving the

    tribunal or the Court this power. However, if the parties agree to invest the

    tribunal with such a power, then we would have no objection.

    181. Having said this, the DAC appreciates the common sense behind the

    suggestion. We are persuaded, however, that the problem is best solved by

    obtaining the agreement of the parties. Thus those who are in charge of

    drafting standard forms of contract, or who offer terms for arbitration

    services which the parties can incorporate into their agreements, (especially

    those institutions and associations which are concerned with situations in

    which there are likely to be numerous contracts and sub-contracts) could

    include suitable clauses permitting the tribunal to consolidate or order

    concurrent hearings in appropriate cases. For example, the London Maritime

    Arbitrators Association Rules have within them a provision along these lines.

    In order to encourage this, we have made clear in this Clause that with

    the agreement of the parties, there is nothing wrong with adopting such

    procedures."

    45. With regard to United States law, a collection of decisions, almost all of

    federal courts, were cited in argument for the respondents, viz.

    Thomson-CSF, SA v American Arbitration Association 64 Fed 3rd 773 (U.S.

    Court of Appeals, Second Circuit, 1995); Federated Department Stores Inc v

    JVB Industries Inc. 894 F 2nd 862 (United States Court of Appeals, Sixth

    Circuit, 1990); Fried, Krupp GmbH v Solidarity Carriers Inc. 674 F Supp

    1022 (United States District Court, S D New York, 1987); 674 F Supp 1022

    (United States District Court, S D New York, 1987); Stamey v Easter 2000

    WL 869577 (Alabama Supreme Court, 2000); MS Dealer Service Corp. v

    Franklin 177 F 3rd 942 (United States Court of Appeals, Eleventh Circuit,

    1999); Morris v Chesapeake & OSS Co. 125 F 62 (District Court, S D

    New York, 1903); Carte Blanche (Singapore) Pte Ltd. v Diners Club

    International Inc. 2 F 3rd 24 (United States Court of Appeals, Second

    Circuit, 1993); and Moses H Cone Memorial Hospital v Mercury Construction

    Corporation 460 US 1, 103 S Ct 927 (Supreme Court of the United States,

    1983). Their Lordships have read these cases. Some of them show a readiness

    in arbitration matters to pierce the corporate veil or apply the concept of a

    third party beneficiary, but there appears to be no clear instance of a party

    who has not consented and is not estopped being held bound to arbitrate with a

    claimant who is not a party to the arbitration agreement. The American

    authorities are of limited assistance on this issue of jurisdiction. Indeed

    counsel for the respondents, who argued (without objection) for restoration of

    the decision of Ground CJ upholding the award to both Cavalier Bahamas and

    Cavalier TCI, based the argument ultimately on article 4.9.5 of the general

    conditions of contract.

    46. Such a rule of an arbitral institution may of course, by incorporation,

    amount to express or implied consent to extension of the arbitrators'

    jurisdiction by their own order. The basic criterion remains consent. This

    principle was seen at work in the House of Lords case Lafarge Redland

    Aggregates Ltd. v Shephard Hill Civil Engineering Ltd. [2000] 1 WLR 1621.

    It was a case of separate contracts, each with its own arbitration clause,

    between employer and main contractor and main contractor and subcontractor. An

    institutional rule, applying when disputes arising under more than one contract

    were concerned with the same subject-matter and were to be dealt with by the

    same arbitrator, empowered the arbitrator to order that they be heard together.

    The contractor sought to compel the subcontractor to accept and wait for a

    composite hearing. But the subcontractor's consent to that procedure,

    contained in the subcontract, was held to be conditional on the contractor's

    taking the necessary steps within a reasonable time. It was also accepted that

    the employer could not be compelled to take part in a joint hearing: the

    employer was not a party to the subcontract and had not otherwise consented.

    47. The question is whether article 4.9.5 constituted consent by The Bay to

    the vesting in the arbitrators of power to join Cavalier TCI. As has been

    seen, the courts in the Turks and Caicos Islands, for somewhat differing

    reasons, thought that it did. They saw it as an empowering clause, which is

    the argument of Mr Reese QC. The Board is unable to agree. The clause has to

    be read as a whole. Throughout it is concerned, as its introductory heading

    indicates, with limitation on consolidation or joinder. It is not a

    source of jurisdiction, but a restriction of jurisdiction. It presupposes

    relevant agreements to arbitrate, which will be the source of any jurisdiction

    that does exist, and it imposes conditions on the exercise of any powers of

    joinder that may otherwise flow from such agreements. The various references

    to consent and agreement are consistent with this theme. There is a

    prohibition against including parties other than the owner, contractor, other

    contractors and other persons substantially involved in a common question of

    fact or law whose presence is required if complete relief is to be accorded in

    arbitration. Their Lordships cannot extract from this prohibition the positive

    conferment of jurisdiction to add a claimant who is not a party to the

    arbitration agreement and to whose joinder a party to that agreement

    objects.

    48. Nor does the Board find it possible to adopt the half-way house, proposed

    by the Court of Appeal, of jurisdiction to join Cavalier TCI but not to make an

    award in its favour. The concept seems self-contradictory. If a party is

    properly joined as a claimant, it is difficult to see how it can be denied

    relief as a claimant. There is nothing in the unreported judgment of Hobhouse

    J in Phoenican Express SARL v Garware Shipping Corporation Ltd. (Queen's

    Bench Division, 22nd November 1983) to support such an illogical course. That

    case is a straightforward example of the setting aside of an award insofar as

    it purported to be in favour of a company not a party to the submission to

    arbitration. There was no separate question about joinder. The judgment is,

    however, helpful as illustrating severance (although that point was not argued

    in that case).

    49. For these reasons it must be held that the arbitrators lacked

    jurisdiction, not only to make an award in favour of Cavalier TCI but even to

    make it a party to the arbitration. Cavalier TCI should consequently be struck

    out from the award, which, subject to the no loss point, is to be upheld in

    favour of Cavalier Bahamas only.

    The Issue of Loss

    50. It has consistently been contended for The Bay that Cavalier Bahamas

    suffered no loss and that in making an award to Cavalier Bahamas the

    arbitrators were guilty of misconduct (in the technical sense) by disregarding

    that argument. While the appeal to the Privy Council was pending the House of

    Lords on 27th July 2000 decided Alfred McAlpine Construction Ltd. v Panatown

    Ltd. [2000] 3 WLR 946. The majority speeches in that case are now said to

    provide further support for the argument.

    51. In Panatown a group of companies wished to have a building

    constructed. The land was owned by one company in the group (UIPL) but, for

    avoidance of value added tax, the building contract was made by another member

    (Panatown). A collateral deed was entered into between the contractor and UIPL

    whereby the latter was given a direct remedy against the contractor for failure

    to exercise reasonable care and skill. The building proved seriously

    defective, but by a majority of three to two the House of Lords held that

    Panatown, the only claimant in an arbitration, was entitled to no substantial

    damages because it had suffered no loss. The collateral deed was a major factor

    in this decision. For present purposes the speeches, which are naturally

    elaborate, have been summarised only briefly. A more extensive review is to be

    found in Professor Brian Coote's article, "The Performance Interest,

    Panatown, and the Problem of Loss" in (2001) 117 LQR 81-95. He brings

    out some anomalies and says that it would be a great pity if the decision in

    Panatown were taken to be the last word. Given the complexity of the

    authorities, the Board sees little likelihood of that.

    52. Panatown did not concern a claim by a building contractor. Neither

    in Panatown or elsewhere can their Lordships find any basis for a theory

    that a building contractor who completely delegates performance of the work is

    thereby necessarily debarred from recovering either contractual remuneration or

    damages for the employer's breach. If the work is in fact performed by an

    associated company or a subsidiary, the financial arrangements between that

    company and the contractor may produce the result that any loss falls on the

    contractor. There was uncontradicted evidence in this case to the effect that

    such was the position. The obvious inference from the joinder (without

    jurisdiction though it was) is that the arbitrators accepted that view of the

    matter, treating Cavalier TCI as the alter ego of Cavalier Bahamas. (According

    to the witness statement of leading counsel for The Bay, Mr Scott, they said

    that to all intents and purposes Cavalier Bahamas and Cavalier TCI were part

    and parcel of the same company, or were alternatively alter egos.) Questions

    of law and fact were for the arbitrators. There is no trace of any error of

    law or fact, let alone of misconduct of any kind, in their award to Cavalier

    Bahamas. The suggestion that they must have ignored the no loss argument is

    improbable and unfounded. They were entitled to be unimpressed by it. That

    award should stand.

    The Issue of Interest

    53. Although no reason is apparent for denying the contractor interest on the

    award to the date of leave to enforce it as a judgment, whether to allow a late

    amendment was a discretionary question on which the Board is unwilling to

    interfere with the decisions of the courts of the Turks and Caicos Islands. It

    is open to the contractor to bring separate proceedings for the interest now

    claimed.

    Disposition of the case

    54. For these reasons their Lordships will humbly advise Her Majesty that the

    appeal ought to be dismissed but that the joinder of Cavalier TCI as a party to

    the arbitration ought to be set aside, leaving standing the award to Cavalier

    Bahamas and the leave to enforce it as a judgment. The cross-appeal should be

    dismissed without costs. The appellants should pay Cavalier Bahamas the costs

    of the appeal.

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    Bay Hotel and Resort... v. Cavalier Constructio...
    (Jul 16, 2001)