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Valuation negligence or breach of duty 

09-02-2026 10:43

There are a lot of materials on isurv on this matter which look at a range of case law. 

https://www.isurv.com/info/1367/negligence_in_valuations_and_surveys

Most recently there was

[2025] EWCA Civ 562 (2 May 2025)
And the Court of Appeal case of 
 
The High Court stated 
‘i) For a valuer, like any other professional, to be found to be liable for professional negligence it is a fundamental "Bolam" requirement that they be found to have acted otherwise than in accordance with practices which are regarded as acceptable by a respectable body of opinion in the profession, recognising that there is scope for differences of reasonable professional opinion, and that the process of professional valuation is an art as much as a science;
ii) But it is, in any event, a precondition of liability that the valuer's valuation should fall outside the range permitted to a non-negligent valuer in respect of that particular type or kind of valuation.’

and the Appeal Court clarified that the permissible margin for error was plus or minus 15% of the true value. Jones’ valuation—14.15% below the true value—fell within that permissible bracket so he could not be in breach of duty.

Valuation is a matter of professional judgment and different competent valuers may reasonably reach different conclusions.

isurv - negligence in valuations and surveys
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