... of Lords stated that a 'special relationship' must exist between the claimant and defendant so that the claimant placed reasonable reliance, which was known, or ought to have been known to the defendant, on the statement. Lord Morris stated that the defendant needed some special expertise in order for there to be a special relationship- the defendant needs to be in a better position then the claimants to know the facts. If they are on equal footing then it is unlikely for there to be a special relationship. It was thought initially by the Privy Council that the claimant needed to show that the defendant's business was the giving of the advice in which the defendant has special expertise3 However, the Court of Appeal in Esso Petroleum v Mardon4 deliberated that there was no need for the defendant to be in the business of giving that advice. This approach was avowed in ...

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