The Bellgrove v Eldridge cost of rectification measure of damages for defective building work is not displaced merely because the defects do not diminish the value of the property or because the property has been sold. The measure is displaced only where supervening circumstances show with substantial certainty that rectification will not happen. Where the sale price was reduced by an amount exceeding the cost of rectification on account of the defects, the sale does not displace the Bellgrove measure. The proposition that no damages should be awarded if rectification work will never be carried out should not be taken unqualified and out of context.
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