Section 18C of the Home Building Act 1989 (NSW) is to be construed distributively: a successor in title acquires separate causes of action against the developer corresponding to each building contract, not a single cause of action for all work. The seven-year limitation period under s 18E runs from completion of the work under the particular contract that is the subject of the claim, not from completion of the last work done on the development. Whether a s 18C claim is an apportionable claim under s 34 of the Civil Liability Act 2002 (NSW) was left open, though the Court indicated there is much to be said for the view that it is not.
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