A valuer or surveyor who carries out professional work will almost invariably owe a duty of care and skill to the client, either as an express or implied term of the contract under which the work is to be done or, in the common situation where there is no such express term, as a term implied into that contract. If the work is not carried out to the required standards of reasonable care and skill, this will constitute a breach of contract. The client may also be entitled to claim under the tort of negligence. Surveyors will be able to advise on duty of care, breach of duty, defences, and mitigation and contribution in negligence cases, and provide advice on the extent of liability for negligence; damages for negligent surveys and the 'margin of error' approach to establishing negligence against valuers.