Pure Economic Loss & Negligent Misstatements in United Kingdom and Malaysia 2

Pure Economic Loss & Negligent Misstatements In
United Kingdom and Malaysia
INTRODUCTION
Until the middle of the twentieth century the tort of negligence was very largely
concerned with careless conduct resulting in personal injuries or damage to property. This
essay explores ways to study the major growth areas of the last 50 years. As a matter of fact,
the tort of negligence is often quite difficult for the following reasons. Firstly, there is a large
volume of new case law. Secondly, there are conflicting policy aims and objectives. Thirdly,
we need to remember that this is a policy device and different judges would take different
view at different time. So, the cases are always totally consistent.
In this essay, we will also be looking at duty of care for pure economic loss and
negligent misstatement. It is important to make sure for us to understand the law in this area
and policy that drives it. In addition, we need to understand various situations under which
pure economic loss might arise and we need also try to appreciate any cause for reform.
This essay will proceed in nine parts. Part I explores briefly on historical view of
negligent misstatements and pure economic loss. Part II explores the meaning of pure
economic loss. Part III explores the recovery of pure economic loss in policy consideration
context. Part IV analyses the economic loss cases on negligent misstatements. Part V explains
economic loss cases on performance of a service. Part VI explains economic loss cases on
damage to anothers property. Part VII explains the current test in Malaysia in determining for
negligent misstatement as a comparison with United Kingdom (hereinafter known as UK).
Part VIII explores any possible reforms in UK and Malaysia. And, lastly Part IX is a
conclusion.

Part I: Pure Economic Loss and Negligent Misstatements

We start at liability for pure economic loss and for negligent misstatements. It is
important for us to remember that these are technically two areas of duty of care. They do not
always go together. There are problems of duty of care in respect of pure economic loss. And,
there are problems for duty of care for negligent-misstatements.
Now, many cases in real life concern both of these issues at a same time. But, it is
possible to have a case that only involves pure economic loss or involves liability for
statements.
Hedley Byrne v Heller1 as a starting point which is a landmark House of Lords
decision on negligent-misstatement. In this case, the defendant (D) bank made a statement
about creditworthiness of a company to the claimants bank who then passed down to
claimant. For the purpose of this case, the statement was argued to be negligent. The claimant
relied on the statement and took large advertising campaign for the company but then did not
get pay when the company became bankrupt.
Then, the claimant tried to sue the defendant bank for their careless statement. This case
caused problem in relation to duty of care because the damage that been inflicted by careless
words which would long been regarded as problematic. The court took the view that it was
too onerous to make people liable for their careless statement for their everyday
conversations. Because, this would;
a) open the floodgates
b) it would be unfair
c) and potentially recourse never lunch of litigation
1 [1963] 2 All ER 575 (HL).

2

Now, Hedley Byrne v Heller2 is a case that happened at the time of House of Lords
viewed itself absolutely bound by its previous decisions. In addition, there had been tendency
until that point to take the view that there was no liability, no duty of care of careless words.
Instead, the claimant would have to show dishonesty.
However, in Hedley Byrne v Heller,3 House of Lords said this was misunderstanding
over its earlier decisions in Derry v Peek,4 saying that Derry was a case based on tort of
deceit. And, therefore, it was not binding in negligent.
On top of that, House of Lords thought that they could potentially be a duty of care for
careless words. But, there is a need of much more restrictive test based on;
a) special relationship
b) reasonable reliance
The degree of foreseeability is such that it is from the fact alone than the requisite
proximity can be deduced. Although on the facts of Hedley Byrne v Heller,5 there was no
actual duty because the defendant gave an advice, clearly making it was without
responsibility.
2 Hedley Byrne (n 1).

3 Hedley Byrne (n 1) 581.
4 [1886-90] All ER Rep 1 (HL).
3

However, Hedley Byrne v Heller,6 does pave a way for duty of care for statements in
certain circumstances. It also important to realise in Hedley Byrne v Heller7 that losses were
pure economic loss which is again problematic kind of damage. The courts would concern
with pure economic loss cases because they potentially open a floodgates. They potentially
could be fraudulent or exaggerated claims. And, there are lots of policy considerations in play.
On top of that, Lord Pearce observed that some difference between the law of
negligent misstatements and that in negligent acts was clear. Negligent misstatements created
difficulties different from those of negligent in act.8

8 Hedley Byrne (n 1) 613. And, Lord Reid put forth the view that the law must treat
negligent misstatements differently from negligent acts and the law ought to be within
the standards of the reasonable man as decided in Donoghue v Stevenson [1932] AC
562 (HL).

Part II: Meaning of Pure Economic Loss

In this part, we explore the meaning of pure economic loss. It is easy to understand by
start considering physical damage. It is the easiest kind of damage to bring a claim for.
The term of pure economic loss that must be distinguished from economic loss where the
former may be claimed in a tortious action where it flows not from personal injury or property
damage.
The court is quite happy for duty of care to exist for physical damage. So, in Spartan
Steel and Alloys Ltd v Martin and Company (Contractors) Ltd,9 the damage metal is
physical damage. Only value that physical damage by reference to cost of metal or in cases of
something than can be repaired, the cost of repair. The damage metal could be sold and usual
profit not made. The loss profit on damaged metal was economic loss consequent on physical
damage and recoverable.
9 [1973] QB 27 (CA). The facts are as where the defendant negligently cut off
power to the claimants factory which caused metal that had been processed at
the time, to solidify and been ruined.
5

However, pure economic loss in another hand is purely financial or economic in nature. Its
loss is not directly link to any physical damage to the claimant or to the claimants property. It
can take in many forms and it can be in;
i)
purely financial loss. As like in Hedley Byrne v Heller10 where bad investment of
ii)
time for which the claimant did not get paid; or

it can be where in purely financial loss like the loss in heritance suffered by the
beneficiary in Ross v Caunters11 and White v Jones12.
The second form of pure economic loss is lost profit in a shutdown as can be seen clearly
in Spartan Steels case.13 Moreover, the loss for pure economic loss is the cost of repairing
inherently defective property or reduction in value when we discover that we have inherently
defective property.
This is the result in the case of Murphy v Brentwood District Council 14 facts that
overruled Anns v London Borough of Merton15. Lord Bridge at this point who said in his
speech;

11 [1980] Ch 297 (HC).
12 [1995] 2 AC 207 (HL).
13 When the electricity was cut off, the metal solidified, so this was physical damage. The
metal was cleaned away and then the factory owners had to seat idly by waiting for the
electricity to come back on. The loss profit in the period that they sat idly by waiting for
electricity is pure economic loss.
14 [1990] 2 All ER 908 (HL).

15 [1977] 2 All ER 492 (HL).
6

...purely economic loss...is only recoverable in contract or in tort by reason of some
special relationship of proximity which imposes on the tortfeasor a document to
protect against economic loss.16
Part III: The recovery of pure economic loss : policy consideration

The general rule is pure economic loss is irrecoverable. In fact, the courts are almost paranoid
about it.
It can be seen that the law put less value on economic loss than it does to property or
person. This is to improve a duty for pure economic loss would be onerous because such
losses as list of policy reasons shown below that;
i)
ii)
iii)
iv)
hard to calculate
hard to verify
open to floodgates
open to fraudulent exaggerated claims
16 Murphy (n 14) 927.

7

On top of this, there are also policy concerned about encouraging the right altitude,
about the role of insurance, and the role of self-protection.
Part IV: Economic loss cases (i) : Negligent-misstatements

So, the general rule that pure economic loss is irrecoverable. But, there are exceptions
to that rule. The main one is if we can bring the case within the rule of Hedley Byrne v
Heller17. Now, we have to go back to Hedley Byrne v Heller18 and see whether there could be
a duty of care for negligent-misstatement and in that context, the duty could also cover the
duty of pure economic loss.
House of Lords always insisted that we could not just rely on foresight of harm created duty
for words. Instead, there must be a special relationship and reasonable reliance. In addition,
special relationship possessed certain hallmark.
8

Firstly, as far as special skill or knowledge is concerned, we know that that would be
liability for everyday conversation between ordinary people. And, in Hedley Byrne v Heller,19
Lord Morris said on the need of special skill or knowledge, whether the defendant in a better
position to know what he is talking about than the claimant.20
However, that was not the case though in Court of Appeal decision in Esso Petroleum
Co v Mardon21 where it was held that it was sufficient for the defendant held themselves out
as having special skill or knowledge.
Secondly, the next requirement in Hedley Byrne22 is there to be a formal considered

advice rather than casual of cast a remark. As in Hedley Byrne,23 they talked about this being
made a contract without the need for consideration i.e the offer and acceptance of an advice
where it can be argued when the parties may have an intention to create legal relations.
The third aspect of special relationship comes in the case of Caparo v Dickman,24
stated that in addition to reasonable foreseeability, a relationship of proximity had to be
established and the imposition of a duty must be fair, just and reasonable. And, where it was
20 Hedley Byrne (n 1) 594.
21 [1976] 2 All ER 5 (CA).
24[1990] 1 All ER 568 (HL).
9

held that there cannot be a duty of care for general statement made to the world at large. That
this could be used for any number of difference reasons. That would be too onerous or would
open floodgates. Instead, it would be liability if the defendant gives specific advice for
specific purpose.
In Heller Byrne v Heller,25 the court was also looking at the context of the advice
being given with the assumption of responsibility. If we remember in this case, the advice
was given clearly without responsibility. And the House of Lords said based on the facts,
that prevented the duty of care arising. But, that does not mean that every defendant could
give advice using these two magic words without responsibility, and thereby, avoid liability.
In Smith v Eric Bush,26 the House of Lords said such clauses if the defendant was a
business X, defendant was subject to section 2 Unfair Contract Terms Act 1977 (UCTA
1977).27 This section says, the business X cannot avoid liability on the death or personal
injury. And can only avoid liability for other damage if it could be reasonable to do so.28
Now, in Hedley Byrne,29 the bank gave free advice whether there were no obligation to
give advice at all. That might be reasonable for without responsibility clause to stop the duty
of care. But, if the defendant charges for the advice, it gains to make such a clause less likely
to be reasonable.

26 [1989] 2 All ER 514 (HL).
27 Unfair Contract Terms Act 1977, s 2.
28 Unfair Contract Terms Act 1977, s 2(1).
10

Part V: Economic loss cases (ii) : Performance of a service

Now, Hedley Byrne30 has paved a way for other cases where the duty of care have
arisen, making the defendant liable for statements. But in slightly different circumstances.31

31 In following cases, the defendant has made a statement to someone, that call him X,
that someone had relied on the statement but it is not X who suffers the loss. Instead, Xs
reliance causes loss to the claimant.
11

Now, in Ministry of Housing v Sharp32, the Ministry of Housings statement to the
prospective purchasers about charges on property caused loss to the claimant. Where they
carelessly left the claimant charge of the statement they made. There was a duty because the
defendant breached statutory duty.
In Ross v Caunters33 where the solicitor breached fiduciary duty in relation to advice
they gave about witnessing a will. The advice was given or instruction was given to testator.
But it caused loss to the claimant. Therefore, there was a duty of care.
And, similarly in Spring v Guardian Assurance Plc,34 although the claimant did not
rely on the advice, it was relied on by the prospective employer who did not give the claimant
the job. Give the important of preferences todays age, and inadequacy of the information of
remedy, the House of Lords thought that the duty of care should arise.
Hedley Byrne35 also expanded in the field of providing professional services. So, in
Henderson v Merret Syndicate Ltd,36 there was a liability to the lords names because the
defendant had assumed responsibility to provide reassurance services, professionally and
reasonably.
Similarly, in White v Jones,37 the solicitor had assumed responsibility to provide his
services and prepare a will for the testator. This gave rise to a duty of care for the
32 [1970] 1 All ER 1009 CA.
33 [1980] Ch 297 HC.
34 [1994] 3 All ER 129 HL. The ex-employer owed a duty of care to the claimant
for the job preference they gave about the claimant to prospective employer.
36 [1994] 3 All ER 506 HL.
12

beneficiaries, who did not inherit because of the will was not prepared in time before the
testator death. It was because the solicitor was well aware that the beneficiary would be
relying on the solicitor to discharge his or her functions with due care.
Part VI: Economic Loss Cases (iii) : Damage to anothers property
37 [1995] 1 All ER 691 HL.

13

We return to pure economic loss but outside the Hedley Byrnes38 context. We saw the general
rule that the courts are reluctant to impose a duty of care for pure economic loss as in Spartan
Steels case.39
Now, having said that pure economic loss is not usually recoverable, by viewing good rules in
tort, there are lots of exceptions. We have seen exceptions in Hedley Byrne v Heller,40 we
have also seen that pure economic loss could be recovered in Ministry of Housing v Sharp41
if there is a breach in statutory duty and there is a breach in fiduciary duty in Ross v
Caunters42 although there could be an exception based on House of Lords decision in Junior
Books Ltd v Veitchi Co Ltd.43
The Junior Books case was not overruled, although its correctness has been doubted
by the House of Lords.44

39 Spartan (n 9). This can be seen also in Weller v Foot and Mouth Disease
Research Institute [1965] 3 All ER 560 (QB), where the autioneer lost profit because
they were not able to auction cattle after outbreak of foot and mouth disease caused by
carelessness of the defendant. That loss of profit in shutdown was irrecoverable. There
was concern that floodgates would be opened and this reluctant to allow a duty for pure
economic loss. Occurs not just in relation with loss profit of shutdown but also in relation
to loss in associated inherently defective property as explained in Murphy v Brentwood
[1990] 2 All ER 908 (HL).

41 Sharp (n 36).
42 Ross (n 37).
43 [1983] 1 AC 520 (HL). Unfortunately for House of Lords, every subsequent cases
limited the ratio in Junior Books although it is never been overruled, it has been
criticised and severely limited.
14

However, House of Lords in this case intended it to be a landmark decision, said that
pure economic loss could be recovered if there was;
a) a relationship of sufficient proximity between the claimant and the defendant45
b) if pure economic loss was reasonably foreseeable46
c) There was no policy reason to preclude recovery47
In The Aliakmon48 and Candlewood Navigation Co.,49 the courts insisted that the
claimant can only use Junior Books50 if the claimant had suffered some physical damage as
well.
44 In this case, the defendant was a specialist flooring contractor who laid the
floor badly in the claimants premises. The claimant did not have a direct contract
with the defendant instead the claimant had a contract with the main contractor
who sub-contracted to the defendant. The cost of replacing the inherently
defective flooring and the loss of profit while the factory shutdown to enable that
to happen, are pure economic loss. Normally, it is recoverable.
45 A relationship of sufficient proximity between the claimant and the defendant, where
in this Junior Book describes as a unique out of ordinary relationship. Contrasting with
Spartan Steel one, where the parties did not know each other, never met each other,
but were thrown together by the accident. In Muirhead v Industrial Tank Specialities
[1985] 3 All ER 705, the courts talked about the need of some reliance by the claimant on
the defendant.
46 The second requirement by pure economic loss being reasonably be foreseeable, it is

not too difficult.
47 But the third requirement, that there being no policy reasons to preclude
recovery, have led the courts to make substantial inroad and limitations on
Junior Books.
48 Leigh & Sillavan Ltd v Aliakmon Shipping Corporation [1986] AC 785 (HL).
49 Candlewood Navigation v Mitsui OK Lines [1986] AC 1 (PC).
50 Junior (n 47).
15

Then in, Simaan General Contracting Co v Pilkington Glass51 the Court of Appeal
said, that Junior Books52 can only be used if it was not being used to circumvent valid
contractual change of liability53. The loss was pure economic loss and the Court of Appeal
said it was not the subject of a duty.
We have to contrast in the case of Anns v Merton54 with Junior Books55 where although there
was a gained, the claimant main contractor and the defendant sub-contractor, there was no
valid contractual change of liability in Junior Books56 because the main contractor gone
bankrupt and was not worth suing.
51 [1988] 1 All ER 791 (CA).

52 Junior (n 47).
53 In Simaans case, the claimant had a contract with the main contractor who
sub-contracted to the production of very unique glass to the defendant. The glass
was inherently defective. The claimant did not want to sue the main contractor
for breach of contract, because they did lots of work on another projects with
them. So, they tried to go around the contract and sued the defendant in tort.
54 [1977] 2 All ER 492 (HL).
55 Junior (n 47).
56 Junior (n 47).
16

Part VII: The current test in Malaysia in determining for negligent

misstatements
Malaysia takes a different path for developing their own law of negligent by disapproving the
approach in Murphy Brentwood.57 This happened in 1997 in Dr Abdul Hamid Abdul Rashid
v Jurusan Malaysia Consultants58 where Mr Justice James Foong (as he was) urge preferred
not to follow English precedent as he thought it could create injustice to the Malaysian
citizen.
57 Murphy (n 14).
58 (1997) 3 MLJ 546 (HC). Where it was presided by Judge James Foong (as he
was) after reviewed the position of other common law countries such as Canada,
New Zealand, Australia and Singapore in relation to pure economic loss.
17

The decision from the learned judge was heavily influenced by the approach of Canadian
Supreme Court in Ultramares Corp v Touche.59 On top of that, a claim for economic loss is
not limited to defective property but has far affected in all situations as to avoid inequity. This
decision has been followed in the case of Stephen Phoa Cheng Loon & Ors v Highland
Properties Sdn Bhd & Anor.60
On appeal in Majlis Perbandaran Ampang Jaya v Stephen Phoa Cheng Loon & Ors,61 the
Federal Court allowed the fourth defendants appeal where it was not fair, just and reasonable
to impose the city council (MPAJ) for after collapse losses suffered by the claimants. This
decision shows that the possibility of succeeding in a pure economic loss suffered as a result
of the local authorities negligent is irrecoverable.
Therefore, the pure economic loss may be recoverable if there is an assumption of
responsibility in relation of loss suffered by the claimants to establish the proximity and
foreseeability which are necessary between the relation of both parties.
59 (1932) 174 NE 441 (SC)

60 (2000) 4 MLJ 200 (HC). According to James Foong J, in order to avoid injustice of the
doctrine of pure economic loss, based his decision of the Canadian Supreme Court that to
impose liability on the tests of proximity and foreseeability of loss to an identifiable
plaintiff.
61 (2006) 2 MLJ 389 (FC)

18

Part VIII: Possible Reforms in UK and Malaysia

As far as UK are concerned, there is no new proposal put forward by the Law
Commission or the government. However, it is worth to look the recent case in House of
Lords in Customs and Excise Commissioners v Barclays Bank plc.62 In a unanimous
62 [2006] 4 All ER 256 (HL). In this case, the commissioners seek damages for the loss
which they claim to have suffered as a result of Barclays negligence in authorizing the
payments after being notified of Mareva injuction order. Where it was assumed that the
respondents owed a duty of care to the commissioners. Judge Colman held that they did
not ([2004] 2 All ER 789 HC), but the Court of Appeal held that they did ([2005] 3 All ER
852 CA).
19

decision, the House in the present case found itself in the familiar position where the court
faced a novel situation and applied the threefold test as decided in Caparos case.
According to Lord Walker, the House recognised the threefold test in Caparos case
is labels, and that their usefulness is limited. 63 On top of that, in judgment by Lord Mance, he
says that an assumption of responsibility is a core area of liability for economic loss which
derives from Hedley Byrnes case.64 The House concluded that no such duty arised.
In Malaysia, the recent case can be seen in a later case of The Co-Operative Central
Bank Ltd v KGV & Associates Sdn Bhd 65 where Federal Court unanimously agreed and
approved the correct approach in Ampang Jayas case.66 As Court of Appeal decided that the
existence or not of a duty must be based on the facts and circumstances of a particular
relationship between the parties which eventually lead to a correct finding. They are also
approved the approach of three-test as laid out in Caparos case.67 Therefore, the courts or
judges have been consistently applying the correct test since a landmark case decided by Mr
Justice James Foong.
Part IX: Conclusion

Consequently, pure economic loss may be recoverable if there is an assumption of
responsibility in relation to the loss suffered by the claimant and need to establish proximity
63 Ibid [72] (Lord Walker).
64 Ibid [85] (Lord Mance).
65 (2008) 2 MLJ 233 (FC)
66 MPAJ (n 65)
67 Caparo (n 28).
20

of the necessary relationship between the disputed parties. In the absence of an assumption of
responsibility the courts will take further consideration and consider based on the
circumstances of the case and decide if it is fair and reasonable to impose liability for
economic loss.
PRIMARY SOURCES
21

ACTS OF PARLIAMENT (UNITED KINGDOM):

Unfair Contract Terms Act 1977, s 2
CASES:
United Kingdom:
Aliakmon Leigh & Sillavan Ltd v Aliakmon Shipping Corporation [1986] AC
785
Anns v London Borough of Merton [1977] 2 All ER 492
Caparo v Dickman [1990] 1 All ER 568
Candlewood Navigation Co. [1986] AC 1
Chaudry v Prabhakar [1988] 3 All ER 718
Customs and Excise Commissioners v Barclays Bank plc [2006] 4 All ER 256
Derry v Peek [1886-90] All ER Rep 1
Donoghue v Stevenson [1932] AC 562
Esso Petroleum Co v Mardon [1976] 2 All ER 5
Hedley Byrne v Heller [1963] 2 All ER 575
Henderson v Merret Syndicate Ltd [1994] 3 All ER 506
Junior Books Ltd v Veitchi Co Ltd [1983] 1 AC 520
Leigh & Sillavan Ltd v Aliakmon Shipping Corporation [1986] AC 785
Ministry of Housing v Sharp [1970] 1 All ER 1009
Muirhead v Industrial Tank Specialities [1985] 3 All ER 705
Murphy v Brentwood District Council [1990] 2 All ER 908
Mutual Life & Citizens Assurance Co Ltd v Evatt [1971] 1 All ER 150
Ross v Caunters [1980] Ch 297
Simaan General Contracting Co v Pilkington Glass [1988] 1 All ER 791
Smith v Eric Bush [1989] 2 All ER 514
Spartan Steel and Alloys Ltd v Martin and Company (Contractors) Ltd [1973]
QB 27
Spring v Guardian Assurance Plc [1994] 3 All ER 129
Weller v Food and Mouth Disease Research Institute [1965] 3 All ER 560
White v Jones [1995] 2 AC 207
Yianni v Edwin Evans & Sons [1982] 3 All ER 592
Malaysia:
Dr Abdul Hamid Abdul Rashid v Jurusan Malaysia Consultants (1997) 3
MLJ 546
22

Majlis Perbandaran Ampang Jaya v Stephen Phoa Cheng Loon & Ors (2006)
2 MLJ 389
Stephen Phoa Cheng Loon & Ors v Highland Properties Sdn Bhd & Anor
(2000) 4 MLJ
The Co-Operative Central Bank Ltd v KGV & Associates Sdn Bhd (2008) 2
MLJ 233
Canada:
Ultramares Corp v Touche (1932) 174 NE 441
SECONDARY SOURCES
BOOKS:
Rogers W V H, Winfield and Jolowicz on Tort (18th edn, Sweet and Maxwell 2010)
Lunney M, Tort Law: Text and Materials (4th edn, OUP 2010)
Murphy J, Street on Torts (13th edn, OUP 2012)
Markesinis and Deakin, Tort Law (6th edn, OUP 2008)
Weir T A, Casebook on Tort (10th edn, Sweet and Maxwell 2004)
HARD COPY JOURNALS:

United Kingdom:
Barker K, Wielding Occams Razor: Pruning Strategies for Economic Loss 26 OJLS
289
Frame S, Pure Economic Loss (2011) 22 Cons Law 26
23

OSullivan J, Negligence, Remoteness and Economic Loss Staying on Track
(2011) 70 CLJ 496

Pliener D, Outflanking Murphy v Brentwood: Claiming in Tort for Pure Economic
Loss (2010) 26 Const LJ 270

Sarabdeen J, Negligent Liability and E-consumers in Malaysia (2004) 10 CTLR 200
Shorter R, Pure Economic Loss Re-examined (2011) 267 PLJ 22
Stapleton J, Duty of Care and Economic Loss: A Wider Agenda (1991) 107 LQR 249
Watts P, Principals Tortious Liability for Agents Negligent Statements is
Authority Necessary? (2012) 128 LQR 260

Witting C, Distinguishing Between Property Damage and Pure Economic Loss in
Negligence: A Personality Thesis (2001) 21 LS 481
Malaysia
Ali M M, Claimability of Economic Loss: Malaysia Takes A Stand Amid
Inconsistencies (2003) 4 MLJA 178

Andrew P, Recent Development in Singapore Contract Law The Search for
Principle (2012) 2 MLJA 119

Carol G S T, Pure Economic Loss in Malaysia: Following English Law by Default?
(1995) 2 MLJ 439

Grace X, - Donoghue v Stevenson A New Fa Ade for the Construction
Industry? (2001) 2 MLJA 65
Dr Abdul Hamid Abdul Rashid & Anor v Jurusan Malaysia
Consultants (Sued as a Firm) & Ors [1997] 3 MLJ 546: Breakthrough
for Recovery in Pure Economic Loss? (1998) 3 MLJA 26

Kumaralingam A, Liability in Negligence for Purely Economic Loss Caused by
Defective Buildings: Recent Decisions From the United Kingdom, New Zealand,
Canada and Australia (1996) 3 MLJA 101

Saraswathy S, Professional Negligence in the Construction Industry (2009) 2 MLJA
162
Ter K L, Economic Loss Current Principles of Recovery (1992) 1 MLJA 178
Wong W K, - Pure Economic Loss: Hedley Byrne Revisited (PT I) (1995) 2
MLJA 161
Pure Economic Loss: Hedley Byrne Revisited (PT II) (1995) 2
MLJA 177
24

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