The decision in Santos Limited v Fluor Australia Pty Ltd [2025] QSC 184 is one of the clearest reminders yet of what courts expect from delay and programming experts. It shows that credibility is earned through structure, logic, and transparency.

Most disruption claims say very little about what actually changed on site. They talk about loss of productivity in broad terms. This article explores a real project that faced disruption and the approach that should be taken.

This case became the foundation of modern forensic analysis. It reminded the industry that delay, and disruption are not labels but factual outcomes that must be proven with evidence. 

In V601 Developments v Probuild, Justice Digby drew a clear line between delay and disruption. Delay is about time. Disruption is about cost. The two may share causes but they demand different evidence. 

Disruption and delay often come from the same events but they are not the same. Delay concerns time. Disruption concerns efficiency.  V601 and White Constructions were about delay, but their value lies in how they define good evidence.

Santos Limited v Fluor Australia Pty Ltd provides one of the clearest explanations yet of what disruption means, how it must be analysed, and what level of proof the courts expect from experts and parties.

Disruption is an interference that disturbs or slows down a Contractor's usual working methods, leading to reduced efficiency. Disruption is not the same as delay, however a disruption can be the cause of a delay.

Disruption claims provide a pathway for contractors to recover losses caused by inefficiencies on a project. For such claims to succeed, they must adhere to the "common-sense" approach.

Australia’s construction industry is essential to national development, yet it faces significant challenges due to five primary mega-disrupters.

Behaviours and interactions between project stakeholders play a pivotal role in determining the success or failure of a project.

Construction projects, whether it’s building a house or a massive infrastructure project, are never as simple as they seem.

A disruption claim aims to show a decrease in productivity, resulting in additional costs that wouldn't have occurred without the disruptive events the Employer causes.