The standard of care in professional negligence derives from Bolam v Friern Hospital Management Committee [1957] 1 WLR 582. A professional is not negligent if they have acted in accordance with a practice accepted as proper by a responsible body of opinion in that profession. Applied to valuation and surveying, the question is whether the firm did what a reasonably competent practitioner in the same field would have done, not whether a better or more cautious professional might have done more.
In valuation the Bolam standard sits alongside the permissible margin of error. The court asks whether the methodology, the inspection and the reasoning were those of a reasonably competent valuer, and whether the resulting figure fell within the acceptable bracket. A defensible process is a genuine protection: a valuer who followed accepted practice and reached a figure within the bracket is not negligent merely because the outcome was unfortunate.
Following Bolitho v City and Hackney Health Authority [1998] AC 232, a body of professional opinion must also be capable of withstanding logical analysis; a practice that cannot be defended as reasonable will not shield a professional simply because others follow it. And, as Platform Funding shows, some duties, such as valuing the correct property, are not qualified by the Bolam standard at all.
Bolam frames the standard against which surveyor and valuer conduct is judged. Apex explains how documentation and standards feed into cover and claims defence on its surveyors' PI guide, and the parallel position for cost consultants on the quantity surveyors' PI guide. Good records and accepted method are not only good practice; they are the material a defence is built from.
Bolam is only as strong as the record that supports it. A valuer who followed an accepted method and reached a figure within the permissible bracket is not negligent, but proving that after the event depends on contemporaneous notes, a clear methodology and evidence that the process matched accepted practice. The defence is built from documents created at the time, not reconstructed later, which is why disciplined record-keeping is a genuine risk-management measure rather than administrative overhead.
The limits of Bolam are equally important. Following Bolitho, a practice must be capable of logical justification, so a firm cannot shelter behind a common but indefensible shortcut. And some duties, such as valuing the correct property, sit outside Bolam altogether. For cover, the message is that the standard of the reasonably competent practitioner is a real protection, but one that has to be earned through method and records. Firms that value that discipline give themselves, and their insurer, the material from which a successful defence is constructed.
Apex Insurance Brokers Limited is authorised and regulated by the Financial Conduct Authority. Firm reference number 724952. This entry is general information, not advice on any particular policy.