Where a valuer1 knows2 that his report will be shown to a third party who will act in reliance on it, he owes a duty of care in tort to that party3, provided that there is a sufficiently proximate relationship between them4. A duty of care may also be owed by a valuer who ought to know, though he does not actually know, that a third party is likely to rely on his report5, even if the third party is not actually shown the report6, and at least where there is a high degree of probability of such reliance7.
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