Whether an adjudicator has jurisdiction to determine liability for the costs of the parties to the adjudication depends upon the proper construction of any relevant contractual terms or applicable adjudication rules1. There is no power in the scheme for construction contracts2 for the adjudicator to award costs between the parties, and, in general, the adjudicator has no jurisdiction to award such costs, but it has been held that he may be given such jurisdiction by an implied agreement between the parties3.
The adjudicator may not impose a lien on his decision or reasons and refuse to deliver it pending the
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