This should not be unexpected; The omission of a suspension based on “manifest injustice” merely underscored the exceptional nature of the decision in estura. In that conclusion, the Tribunal considered “all the circumstances of the case” and therefore took into account factors beyond the factors identified in Estura as relevant. Those factors included, in a significant context, the factual context in which JRT had submitted its claim for payment, which resulted in a decision by an adjudicator in its favour, and the nature of the amounts claimed in the present application. Read more → Last time, Jonathan talked about some of the lessons he learned in remote dispute resolution. I was thinking of following this up with some thoughts on the distance learning I did this year (for obvious reasons) on expert determination. .