CL-2018-000297, CL-2018-000404, CL-2018-000590, - [2025] EWHC 2364 (Comm)

the defendant made clear by disclaimer that it did not take responsibility for reliance on what it said (as in Hedley Byrne itself), or its statement was otherwise “qualified or explained, for example as a statement of belief rather than fact, or as not having been verified for accuracy or completeness” (McClean v Thornhill [2023] EWCA Civ 466, per Simler LJ (as she was then) at [93]); and

the claimant was independently advised, or could independently verify the information provided, such that the defendant could not reasonably have expected the claimant to rely on its information or advice (ibid, at [89]; see also NRAM, supra, at [19] and [23]).