000			02498nab a22002535a 4500
005			20250512105729.0
007			cu || ||||||aa
008			240614t2024 xxk oo | o000 0 eng |
041	0		_aeng
245	0	0	_aBratt v Jones _h[electronic resource]
260			_aChancery Division (Property Trusts and Probate list) _b[2024] EWHC 631 (Ch), _c22 March 2024
520			_a[2024] EWHC 625 (KB). 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 ‘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.’
520			_aUpheld by CA in judgment of 2 May 2025, neutral citation [2025] EWCA Civ 562
650	0		_aRESIDUAL VALUATION
650	0		_aBRATT V JONES
650	0		_aMERRIVALE MOORE PLC V STRUTT & PARKER
650	0		_aCOMPARABLES
650	0		_aPROFESSIONAL NEGLIGENCE
650	0		_aVALUATION
651		4	_aUnited Kingdom
690			_aValuation _96273
856	4	0	_uhttps://www.bailii.org/ew/cases/EWHC/Ch/2024/631.html _zAvailable on BAILII
942			_n0 _2ddc
999			_c121955 _d121955