Generate a Dispute Summary Document
Create a structured dispute summary covering background, issues, positions, evidence, and recommended resolution.
Editor: Owen HaggerLast updated
Overview
This workflow helps Contracts Managers prepare a comprehensive dispute summary document suitable for adjudication preparation, mediation, or internal review. It organises complex dispute information into a clear, structured format covering the factual background, legal and contractual issues, each party's position, the evidence available, and a recommended resolution strategy.
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Prompt
You are an experienced UK construction dispute resolution specialist. Prepare a structured dispute summary document based on the following: Contract Form: [CONTRACT FORM, e.g., NEC4 ECC Option B / JCT D&B 2016] Relevant Clause References: [CLAUSE REFS FROM THE CONTRACT, if known] Project: [PROJECT NAME AND VALUE] Parties: [REFERRING PARTY] vs [RESPONDING PARTY] Dispute Value: [APPROXIMATE VALUE, e.g., £340,000] Dispute Resolution Stage: [STAGE, e.g., Pre-adjudication / Mediation preparation / Internal review] Background: - Contract award date: [DATE] - Original contract sum: [VALUE] - Current account position: [VALUE] - Key project milestones: [LIST] - Brief project description: [2-3 SENTENCES] Dispute Description: [PROVIDE A NARRATIVE OF THE DISPUTE, e.g., The dispute concerns the valuation of variations to the mechanical services installation. The Contractor claims additional payment of £340,000 for works it considers variations under the contract. The Employer contends the works fall within the original scope.] Key Issues in Dispute: 1. [ISSUE 1, e.g., Whether the revised M&E specification constitutes a variation] 2. [ISSUE 2, e.g., Valuation methodology for the claimed variations] 3. [ISSUE 3, if applicable] Evidence Available: - [LIST KEY DOCUMENTS, e.g., Original tender documents, Revised specification Rev C, Site instructions SI-045 to SI-052, Correspondence chain dated March-June 2025] Structure the document as: 1. Executive summary (1 paragraph) 2. Parties and contract details 3. Factual background and chronology 4. Issues in dispute (each issue as a separate section) 5. Referring party's position on each issue 6. Responding party's position on each issue 7. Analysis of merits (strengths and weaknesses of each position) 8. Evidence summary matrix (document, relevance, which issue it supports) 9. Recommended resolution approach 10. Next steps and timeline Use objective, balanced language. Identify risks and weaknesses in both parties' positions. Use only the clause references I have provided; where a clause is relevant but I have not given its reference, leave a [CLAUSE REF] placeholder. Do not quote clause numbers or case law from memory. State at the top that this summary is not legal advice, and add the note: Check your contract and take advice.
Typical result
~5hby hand~2hwith AI
A cautious typical estimate, including the time to gather the inputs and check the output. It varies with the job.
What it replaces: Writing a dispute summary from a long email trail.
What you still check
- Every fact is backed by a document
- Both parties' positions are stated fairly
- It's reviewed before it goes anywhere. Check your contract and take advice
Use Case
Use when preparing for adjudication, mediation, or senior management review of a construction dispute and you need a clear, structured summary of the issues and merits.
When not to use it
Don't use it as your adjudication submission or as legal advice. It organises what you already know into a summary for internal review or for briefing your advisers. The referral, the claim and any view on the merits need review by someone who knows construction law. Check your contract and take advice.
It's also the wrong tool if you haven't gathered the documents. A summary built from memory and a long email chain will read convincingly and still be wrong. Check with your solicitor before putting their advice or other privileged material into any AI tool, and only ever use a business account with data controls switched on.
Common mistakes
- Writing the chronology from memory instead of from dated documents. Every fact should point to a document.
- Writing your own position as fact and the other side's as opinion. A one-sided summary won't help you judge the risk.
- Letting the tool fill in clause numbers or legal principles. Check every one against the contract, and have anything legal reviewed.
- Losing track of which notices went in and when. Many disputes turn on whether the right notice was given on time.
Frequently asked questions
- Can AI tell me if I'll win an adjudication?
- No. It can lay out the arguments and show gaps in the evidence, but the merits and likely outcome are a judgement for experienced people who know the contract and the law. Treat any outcome range in the draft as a starting point for that discussion. Check your contract and take advice.
- What's the difference between adjudication and mediation?
- Adjudication is a statutory right under the Construction Act for most construction contracts, and the decision is binding until the dispute is finally decided by a court, arbitration or agreement. Mediation is voluntary: a neutral mediator helps the parties reach their own settlement, and nothing is imposed. Check your contract and take advice on which route suits your dispute.
- What evidence do I need for a construction dispute?
- The contract documents, instructions, notices, correspondence, minutes, programmes, site diaries, photos and valuations, all dated. Records made at the time carry far more weight than anything written after the dispute started. An evidence matrix linking each document to each issue shows up the gaps early.
- When should I get a solicitor or claims consultant involved?
- Early, and certainly before you issue anything formal such as a notice of adjudication. Getting advice while your position is still forming is usually easier than repairing a weak one later. Check your contract and take advice, especially on any steps or time limits in the dispute resolution clause.
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