Brownrigg v. Leacy related to a claim for damages by
the plaintiff, Mr Frank Brownrigg, arising from the alleged
negligence of the defendants in respect of valuations they carried
out of his lands in 2007. The court held that auctioneers owe
a duty of care when preparing valuations on behalf of an individual
and that a party who has commissioned a valuation is entitled to
rely on it and to assume that it has been prepared correctly and in
accordance with accepted standards.
In 2007, the plaintiff farmer obtained valuations of his lands
from two separate auctioneers. The first, Aidan Leacy trading
as Phoenix Estates valued the land between €10 million and
€11 million, while the second, Ben Kavanagh Auctioneers,
valued it at €6.9 million. The plaintiff alleged that he
and AIB relied on the valuations in agreeing a loan facility of
€7.7 million for the purchase of neighbouring lands for
€5.9 million. When the only offer of €1 million on his
farm was inadequate for