The Court held that executors in family provision proceedings have a duty to obtain valuations that are accurate and reliable, proportionate to the size and complexity of the estate, and that desktop assessments and limited scope valuations with acknowledged 'significant limitations' do not discharge this duty in a large contested estate. Where a court order requires a 'valuation' of shareholdings, a 'Limited Scope Valuation' — which by the valuer's own definition involves material limitations on the estimate of value — does not comply with that order. The Court also held that deferring valuation disputes to cross-examination at trial was inconsistent with the overriding purpose of facilitating just and expeditious resolution and with promoting settlement through mediation.
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