Short answer is - in earlier case, certifier has immunity only to be overturned later, that certifier has no immunity as he holds a duty of care both as the agent to the employer and an impartial certifier to the contractor. Immunity only applies where there was dispute which called for a judicial decision such as adjudication and arbitration. Good Luck, Architect!
 Chambers v GoldthorpeKB624
 Sutcliffe v ThackrahAC727
DYA+C is set up by Ar. DAVID YEK TAK WAI to undertake resolution of commercial disputes through ARBITRATION and ADJUDICATION, specializing in CONSTRUCTION PAYMENT DISPUTES.
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