19 January 2012
Paratus AMC Ltd and another company v Countrywide Surveyors Ltd [2011] EWHC 3307 (Ch), [2012] All ER (D) 32 (Jan)
In the context of consideration of a valuation report conducted in respect of a property, it was settled law that to find that the valuation had fallen outside the bracket was a necessary condition of liability in negligence. Further, as soon as it was shown that the impugned valuation fell outside the bracket, it would be for the defendant to show that, notwithstanding that the valuation was outside the range within which careful and competent valuers might reasonably differ, he nonetheless had exercised the degree of care and skill which had been appropriate in the circumstances.