The decision in Hadgelias Holdings v Seirlis does not require that every act of a real estate agent and its principal in a sales transaction be characterised as a single set of acts for proportionate liability purposes. Where a vendor has independently contravened s 52 of the TPA by acts or omissions without direct counterparts in the agent's conduct, the agent and vendor are concurrent wrongdoers, and proportionate liability applies. Settlement amounts received for post-acquisition losses (such as failure to collect rentals) are not to be deducted from damages measured at the date of acquisition unless equivalence between the settlement and the capitalised loss is established.
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