Sanderstead Removals Limited v Andrew Mouland (Valuation Officer)

For rating valuation, an adopted tone does not by itself show that the disadvantages of a particular property have already been reflected. The tribunal must assess that claim against the valuation scheme evidence, especially where the scheme covers disparate properties and the adjustments made are unclear. Allowances from other assessments should be weighed against the properties’ actual characteristics and the reasons for those allowances; their amounts are not automatically transferable. End allowances should reflect disadvantages supported by the evidence and not already accounted for in the valuation.

Sanderstead Removals Limited, which occupies a warehouse and office complex used mainly to store customers’ belongings during removals, appealed against the Valuation Tribunal for England’s decision of 20 October 2025. The VTE had dismissed its challenge to the existing rateable value of £174,000 in the 2017 rating list. The company contended for £130,000; Andrew Mouland, the Valuation Officer, proposed £167,000. The parties agreed on a base valuation tone but disputed whether the scheme already reflected the property’s layout, topography, access and security disadvantages. The Upper Tribunal had to determine the appropriate valuation and end allowances.

The appeal was allowed. The rateable value was determined at £149,500.

1. Statutory basis. Under Schedule 6 to the Local Government Finance Act 1988, rateable value is based on the rent the hereditament might reasonably command from year to year on the statutory assumptions. The relevant physical and occupational matters are taken as at the material day, while rental values are assessed by reference to the antecedent valuation date.
2. Whether the tone already reflected disadvantages. The experts agreed a base tone of £55 per m², but the respondent argued that disadvantages common to properties in the scheme were already reflected in that figure. The scheme ranged from £55 to £80 per m², covered disparate properties and did not reveal clearly what adjustments had been made. The Tribunal therefore examined representative assessments and found that the property’s relevant disadvantages were not otherwise accounted for in the valuation.
3. Comparable assessments and allowances. The reason for an allowance and the property’s actual characteristics mattered when assessing comparable evidence; an allowance was not automatically transferable. The Tribunal adopted 7.5% for layout, then allowed a further 2.5% for topography, 2.5% for access and 5% for security. It also adopted the respondent’s allowance for floor-level issues and the agreed adjustments for lack of heating and insulation.
4. Rental evidence and valuation. The freely negotiated 2011 rent provided a reasonableness check, as the property’s disadvantages should be reflected in that rent. The 2021 rent was too remote from the antecedent valuation date to assist. The failure to trigger the 2016 rent review was not known to the occupier at that date. Taking the valuation evidence as a whole, the Tribunal determined the assessment at £149,517, rounded to £149,500.

1. Upper Tribunal (Lands Chamber) — allowed the appeal and determined the rateable value at £149,500.
2. Valuation Tribunal for England — on 20 October 2025, dismissed the company’s appeal against the existing rateable value of £174,000.