According to the House of Lords in South Australia Asset Management Corp. v. York Montague Ltd (hereafter “SAAMCO”)1 and Nykredit Mortgage Bank Plc v. Edward Erdman Group Ltd (No. 2) 2 the correct award is £4m. L can only recover in respect of that part of its loss which is a consequence of the valuation’s being wrong. Although the actual loss suffered by L is £5m, the damages awarded must be restricted to the difference between the valuation provided by V and the correct value of the property at that time: £10m–£6m = £4m. In other words, L is entitled to recover in respect of that part of its loss which does not exceed the difference between V’s valuation and the true value at the time of that valuation. In SAAMCO Lord Hoffmann, with whose speech all of their Lordships concurred, rejected the view of the Court of Appeal that “[t]he lender having, in reliance on the valuation, embarked on a transaction which he would not otherwise have undertaken, the valuer should bear all the risks of that transaction, subject only to the limitation that the damage should have been within the reasonable contemplation of the parties”.3 This went too far because “[n]ormally the law limits liability to those consequences which are attributable to that which made the act wrongful. In the case of