White's expert used the "as-planned versus as-built windows analysis" method in his report. In contrast, SWC/IWS's expert used the "collapsed as-built/but for analysis" method. Each method is referred to in the Protocol, and on this occasion they resulted in profoundly different conclusions. The South Australian case of Alstom Ltd v Yokogawa Pty Ltd (no 7) [2012] SASC 49, which gave weight to whether or not a method was referred to in the Protocol, was considered. However, Justice Hammerschlag rejected the notion that the presence or otherwise of a delay method in the Protocol should be determinative of whether the method is appropriate in any given circumstances. Instead, it was held that "neither method [of delay analysis adopted by the experts for the parties] is appropriate to be adopted in this case". Based upon general legal principles, the onus was on White to prove that the project was delayed by the sewerage design issues and that it suffered loss as a result of that delay. White failed to do so on the balance of probabilities. Central to this finding was that White's expert evidence "assumes causation rather than identifies actual evidence of it". That is, White's expert evidence was insufficient to prove the causal link between the sewerage design issues and the delay to the project overall. Insufficient evidence of consequences of delay To resolve the dispute, a close examination of the actual facts happening "on the ground" was required to determine if the sewerage re-design caused the overall delay, and if so, by how much. In effect, this meant that the Court should apply "the common law common sense approach to causation". White had relied upon an affidavit by a site foreman who gave evidence of "delayed, piecemeal and disrupted" works in an attempt to prove the underlying assumptions in its expert's programming analysis. However, this evidence was too general and it was found that it did not provide sufficient proof of the cause of the overall delay, including by reference to relationships between the activities in the construction program. Separately, a comprehensive site diary was the primary source of evidence as to what was happening "on the ground". However, even the site diary was insufficient. Whilst there were repeated references to delays in the sewer design being finalised and approved, the diary did not "identify the activities, if any, which were being adversely affected by the wait". As a result the diary did not "enable a finding of particular consequences" caused by the sewerage design issues. Consequently, White failed to provide evidence sufficient to prove its claims and they were dismissed. Important takeaways and practical tips An important takeaway from this case is that the mere presence or otherwise of a delay analysis method in the Protocol should not determine its