Litigation Letter
Negligent valuation
Goldstein v Levy Gee (a firm) ChD TLR 16 July
In an action in tort against a professional valuer, even if the reasoning process by which the valuer had reached his figure
was manifestly incompetent he would not be negligent if that figure fell within a bracket of figures which a reasonably competent
valuer could have reached. Where the end figure was made up of a number of independent variables, in order to calculate the
margin of error for the end figure one had to enter the lowest non-negligent figure for each of the variables followed by
the highest non-negligent figure for each variable. In the present case, on that basis, the defendant’s valuation fell within
the permissible margin of error even though the reasoning process by which the figure was reached was manifestly incompetent.