A High Court writ said that Berkeley started work on parts of the Knowle Hospital site before discovering that the ground was unsafe.
The writ said that parts of the large site, which is being developed into residential and commercial units, contained "swallow holes" where the ground collapsed, leaving foundations suspended.
The writ added that Berkeley Homes is suing Leslie Wilks Associates of Tonbridge, Kent, for damages totalling £925,925.09, plus VAT.
Also, according to the writ, work on the site was delayed for more than 22 weeks and grout injections were needed to stabilise 14 plots, at a cost of £313,000. The resulting grievance is that sales of the homes were delayed.
Berkeley argues in the writ that, with proper advice, it would have been able to build away from areas liable to collapse.
The civil and structural engineers acted negligently
Allegation in Berkeley’s writ
The writ said: "The civil and structural engineers acted negligently and failed to review geotechnical reports properly, failed to consider that a ground investigation was not a complete review of ground conditions, and that trial pits did not go down deep enough to penetrate chalk, it is alleged."
Berkeley added in the writ that a ground investigation report prepared in January 2000 by engineering firm PBA warned that the site was at high risk of collapsing, but that Leslie Wilks did not consider it properly.
The writ said that Berkeley Homes had started selling the houses "off plan" – before the properties were built – but wrote to Leslie Wilks Associates in October 2000 highlighting potential problems and suggesting seismic tests or "dynamic probing".
Berkeley Homes called in Keller Ground Engineering to carry out ground stabilisation works, which took four months.
The writ added that the firm also negligently failed to identify the risk of depleted or metastable zones in the gravel, failed to identify true ground conditions and the need for reinforcement foundations and failed to prepare foundation designs to suit ground conditions.
A spokesperson for Leslie Wilks would not be drawn on the case but said that the outcome would depend upon whether the company was aware of the ground conditions at the time.