A valuer's duty of care to a third party lender who relies on a valuation for mortgage purposes does not extend to reliance approximately nine months after the valuation date without any enquiry of the valuer. Industry practice evidence that major lenders accept valuations for only three months, and solicitors for up to six months with telephone confirmation, is relevant to assessing reasonable reliance. The question of whether a duty of care exists is determined by whether the lender's reliance was reasonable in all the circumstances, including the age of the valuation and the absence of confirmatory enquiry.
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