Thanks Focht.
When a test pit was performed near the jet grout wall, almost vertical soilcrete seams were observed within the soft clay. We couldn't go deep enough to see their depth of origin. In jet grouting the high pressures are at the nozzle, by the time you've eroded the soil to the column diameter can't really know what the pressure is. Also, the only way that hydro fracturing could have happened is if the spoils flow got blocked at some point, even temporarily, which would have increased the pressures within the "confined" space.
My first thought was that it would have to overcome the vertical stress of the clay layer, but some papers I read indicate it depends also on the water content, shear strengh and whether NC or OC. I just haven't found a correlation to use and was wondering if anybody knew more. The equation for hydrofracturing in rock does include the tensile strength and lateral stresses.