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Candler v Crane, Christmas & Co [1951]


  •  Accountants negligently prepared a report for a company. The company showed that report to a third party, who subsequently invested and lost money


  • Could the accountants be liable for the negligent preparation to the third party for their loss


  •  No liability


  • No contract therefore no duty
  • Lord Denning dissented, saying there could be a duty if the accountants knew of the transaction (investing) which would result from their statement; in this case they were as they were present at the time the defendant decided to invest
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