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

It has never been a bar to liability that the defendant did not communicate directly with the claimant. As Lord Morris said in Hedley Byrne, at 497: “apart from cases where there is some direct dealing there may be cases where one person issues a document which should be the result of an exercise of the skill and judgment required by him in his calling and where he knows and intends that its accuracy will be relied upon by another”. It is not necessary for the defendant to know for certain that what they say will be passed on, it may be sufficient that they should have realised that it was likely to be passed on; and it is not necessary that their sole purpose in making the statement was that it be so communicated, it may be sufficient for that to have been part of its purpose: Playboy Club, supra, per Lord Sumption at [11].