[2025] EWCA Civ 562, upholds earlier decision in [2024] EWHC 625 (KB) where the claimant claimed damages from the defendant valuer in relation to his valuation of a freehold development site. The claimant argued that the court should reach a determination as to the true market value of the site as at June 2013, and find
that the likely value was £8 million and that the defendant was negligent because his valuation was well outside a 10% margin. The claimant failed to show that the defendant valuer had been negligent where his valuation fell within the bracket of a reasonable range of values, which was plus or minus 15% of the most likely value determined by the court.
The appropriate primary approach to valuation of the site was by reference to comparables, but that should
be cross-checked by a residual valuation, since developer purchasers would have carried out their own detailed residual
calculations in respect of the site, by reference to the anticipated sale proceeds less the costs of construction