Sanderstead Removals Limited v Andrew Mouland (Valuation Officer)

Decision date: 6 July 2026

Neutral citation: [2026] UKUT 247 (LC)

Overall AI summary confidence: high

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Short overview

This short overview is intended to summarise the case, issues and outcome so far as they are supported by the judgment.

AI confidence in this short overview: high

This appeal challenged a VTE decision on the 2017 rating assessment for a former-quarry warehouse and office complex near Godstone, focusing on whether end-of-scheme allowances should reduce the agreed tone of £55/m2 for the hereditament’s specific disadvantages (fragmentation/layout, sloping topography, restricted access and security). The tribunal found the agreed tone did not already reflect all material disadvantages, allowed additional end allowances (composite adjustments including 7.5% for layout, 2.5% topography, 2.5% access and 5% security alongside agreed heating/insulation and floor-level adjustments), and determined a rateable value of £149,500 (revising the assessment down from £174,000). Permission to appeal to the Court of Appeal on a point of law is available in the usual way.

Ratio decidendi

This summary is intended to identify the ratio decidendi, meaning the legal reasons for deciding and the binding part of the decision.

AI confidence in this ratio decidendi summary: medium

The tribunal’s operative ratio is that where a tone of value is broad or derived from a disparate scheme, the tribunal must test whether particular physical disadvantages of a specific hereditament are already reflected in that tone before refusing additional end-of-scheme allowances; comparable assessments relied on to justify or quantify such allowances must be scrutinised for close market and physical comparability and cannot be transferred automatically between materially different hereditaments.

Obiter dicta

This summary is intended to identify obiter dicta, meaning observations made by the way that were not necessary to deciding the case and are not binding.

AI confidence in this obiter dicta summary: medium

The judgment contains obiter observations that a uniform, one-size-fits-all valuation methodology across a diverse valuation scheme can be problematic and may require case-specific adjustments, and that passing rents close to but pre-dating the antecedent valuation date may have limited weight while more remote rents can be of no weight.