A trial judge reviewing a referee's report under r 20.24 of the UCPR must not engage in a substantive reconsideration of factual matters or disagree with the referee on matters of evaluative judgment. The judge must identify a recognised basis for rejection such as misapprehension of evidence, failure to consider relevant matters, error of principle, or perversity in fact-finding. Speculative reasoning as to what 'may well have been the case' does not constitute a proper basis for rejecting a referee's factual findings.
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