The Court held that four invoices enclosed with a single covering letter and served simultaneously constituted a single payment claim for the purposes of s 13(5) of the SOP Act, assessed objectively by reference to the covering letter, the terms of the documents, and surrounding circumstances. The Court also held that s 13(7) does not prohibit the service of more than one supporting statement in respect of a single payment claim, applying s 8(b) of the Interpretation Act 1987 (NSW). The question whether non-compliance with s 13(7) deprives an adjudicator of jurisdiction was expressly left unresolved, with Ball J noting his divergent view from the balance of authority but declining to decide the point.
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