A valuer who makes a valuation which is fraudulent, namely one which he knows to be false or which he makes recklessly without regard to whether it is true or false, with the intention that it should be acted upon, is liable to an action of deceit by any person who was intended to act upon that valuation and who acts upon it to his detriment1. A disclaimer attached to such a valuation will not be effective to exclude or restrict the valuer's liability for fraud
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