CONFIDENTIAL & PRIVILEGED — Prepared in connection with AXA Insurance Claim Ref: 12648569H. Intended solely for the named parties and their professional advisers.

AV/PV/EVIDENCE/2026-03-04/v1.0

Water Damage Evidence

70 High Road, Buckhurst Hill, Essex IG9 5RW

This evidence bundle has been prepared to assist the independent expert in their assessment of the water damage sustained at the above property. It contains photographic evidence, video footage, and supporting technical reports, organised by location.

Insureds: Mr Anish Verma & Mrs Puja VermaInsurer: AXA InsuranceClaim Ref: 12648569HDate of Loss: January 2024

Independent public authority vs insurer

RICS Published Benchmarks vs Cost Assessments

RICS costmodelling.com is the industry's own independent public benchmark tool. The chart below shows that the insurer's figure is inconsistent with the RICS's own published data for Outer London.

RICS costmodelling.com — Median

Independent public authority · 50th percentile · Outer London 2025

RICS Benchmark
£641,520  ·  £2430/m²

RICS costmodelling.com — Lower Quartile

Independent public authority · 25th percentile · Outer London 2025

RICS Benchmark
£498,960  ·  £1890/m²

Revised Assessment — Charles Ramsden Ltd (MRICS)

MRICS Chartered QS · SPONS rates · 108 priced line items

Claimant's Assessment
£329,523  ·  £1248/m²

Independent Contractor Tender — HJ Building & Construction Ltd

Independent market tender · within 1.4% of QS figure

Independent Tender
£324,999  ·  £1231/m²

AXA Internal Review — Terry McKane-Slaughter (AssocRICS)

No SPONS rates · no market indices · visual inspection only · fails RICS standard

Insurer's Assessment
£96,500  ·  £366/m²

The insurer's figure of £366/m² is 81% below the RICS lower quartile — the industry's own lowest published benchmark for Outer London. The claimant's figure of £1,248/m² sits 34% below the same RICS floor. The insurer's position cannot be reconciled with the RICS's own published data.

"Construction cost estimates [for complex reinstatements] should be prepared by appropriately competent professionals with a good grounding in such matters as would be provided by chartered QSs... reinstatement cost assessments should be prepared in accordance with the current edition of RICS' Reinstatement cost assessment of buildings, or to appropriate market indices, which should be clearly referenced in the report."

Steven Thompson BSc MBA FRICS, Senior Specialist, RICS Knowledge & Information Services (December 2025)

RICS Published BenchmarkClaimant's AssessmentInsurer's Assessment
1.0

Damage by Room

Photographic and video evidence organised by location. Each image is captioned with a factual description of what is shown. Click any image to enlarge.

3.1

1st Floor Bathroom

Confirmed

Severe water damage to softwood structures upon strip-out, requiring complete removal of all softwood leading into the passage.

1st floor bathroom — water damage revealed on strip-out

1st floor bathroom — water damage revealed on strip-out

Sub-floor structural water damage — 1st floor bathroom (no underfloor heating in this room)

Sub-floor structural water damage — 1st floor bathroom (no underfloor heating in this room)

Video: 1st floor bathroom — softwood damage requiring removal

3.2

Bedroom 1 (Front)

Confirmed

Removal of a fitted cupboard for rewiring works revealed significant water damage and cracking to the ceiling structure. High moisture readings recorded throughout.

Removal of cupboard reveals significant water damage

Removal of cupboard reveals significant water damage

Water damage extent — ceiling requires full removal

Water damage extent — ceiling requires full removal

Damp walls requiring hacking off

Damp walls requiring hacking off

3.3

Bedroom 2 (Rear)

Confirmed

New cracks appeared post-water escape that were not present before the incident. The ceiling was found to be fragile, necessitating full replacement to avoid future failure.

Significant cracks in Bedroom 2 — occurred after water escape (post-incident)

Significant cracks in Bedroom 2 — occurred after water escape (post-incident)

Overview of Bedroom 2 damage

Overview of Bedroom 2 damage

3.4

Reception Room 2 — Parquet Flooring

Agreed on site — position subsequently changed

Visible surface damage to the original parquet flooring. Upon removal, significant water damage, dampness, and rot were discovered underneath. Note: there is no underfloor heating in Reception Room 2 — the underfloor heating system is located in the through lounge and kitchen at the rear of the ground floor. This item was agreed at the joint site inspection of 29 October 2024 as requiring full replacement.

Ground floor living room — flooring damaged throughout

Ground floor living room — flooring damaged throughout

Ground floor living room 2 — water damage

Ground floor living room 2 — water damage

Removal of floors reveals significant water damage

Removal of floors reveals significant water damage

Underneath wooden parquet flooring — rotten

Underneath wooden parquet flooring — rotten

Parquet flooring — significant damage not visible from surface

Parquet flooring — significant damage not visible from surface

Reception 2 — strip-out works

Reception 2 — strip-out works

Video: Ground floor reception 2 — condition pre-strip-out

Video: Condition of parquet flooring

Video: Damaged flooring underneath

Video: Water damage in Reception Room 2 leading towards the through lounge area

Video: Reception 2 overview

3.5

Reception Room 1 (Living Room 1)

Omitted from scope — 29 Oct 2024

Reception Room 1 was omitted from the scope of the joint site inspection of 29 October 2024. Visible cracking and dampness to the corner of the room, consistent with the escape of water incident, were present prior to strip-out. Wall and ceiling damage confirmed throughout. Upon strip-out, the hardboard flooring was found to be breaking and structurally compromised due to water damage. Photographic and video evidence is provided below.

Reception 1 — overview of damage

Reception 1 — overview of damage

Damaged floor — Living Room 1

Damaged floor — Living Room 1

Water damage to tiles

Water damage to tiles

Partially damaged flooring

Partially damaged flooring

Damaged skirtings — water damage

Damaged skirtings — water damage

Pre-strip — visible damage where water entered flooring

Pre-strip — visible damage where water entered flooring

Pre-strip-out — visible cracks and water damage

Pre-strip-out — visible cracks and water damage

Video: Weakened flooring — removal recommended

3.7

Staircase

Confirmed

Upon removal of the carpet, new cracks were discovered in the stair structure, consistent with water damage from the incident. These cracks were not present prior to the escape of water. The staircase has since been replaced in full as a result of the damage confirmed upon strip-out.

Staircase — overview

Staircase — overview

Stairs after carpet removal — cracks visible

Stairs after carpet removal — cracks visible

Crack on the staircase

Crack on the staircase

Further cracking to stairs

Further cracking to stairs

Video: Multiple cracks in stairs due to water damage

3.8

Electrical Installation

Confirmed

Two independent NICEIC-certified electricians conducted full Electrical Installation Condition Reports (EICRs). Both reports found the installation to be 'Unsatisfactory' and recommended a full rewire. The underfloor heating system in the kitchen and through lounge (at the rear of the ground floor) was also found to have completely failed due to water damage. Replacement of the UFH system requires removal of the existing flooring in the kitchen and through lounge to access the system beneath.

Electrical fixtures — severely rusted and damaged

Electrical fixtures — severely rusted and damaged

Kitchen — rusted electrical fixtures

Kitchen — rusted electrical fixtures

3.9

Downstairs Large Bathroom

Omitted from scope — 29 Oct 2024

This area was not inspected at the joint site inspection of 29 October 2024. Upon removal of wall and floor tiles, considerable dampness and water damage was found on the substrate. Tiles had loosened due to moisture ingress. Photographic and video evidence is provided below.

Moist tiles — floor tiles not adhering

Moist tiles — floor tiles not adhering

Floor underneath tiles — dampness and discolouration

Floor underneath tiles — dampness and discolouration

Corner wall — dampness directly opposite hallway

Corner wall — dampness directly opposite hallway

Video: Corners and walls showing water damage and extreme dampness throughout

Video: Under tiles — moisture and dampness which loosened the tiles

Video: Corners damaged by water — extremely damp

2.0

Photo Comparisons

Side-by-side comparisons highlighting the difference between surface appearance and actual condition upon strip-out. Toggle "Overlay Slider" on any card to drag between the two images.

3.4 — Reception Room 2

Parquet Flooring — Surface vs. Underneath

Key observation: Crawford's visual-only inspection could not detect the rot and dampness beneath the parquet surface — only removal revealed the true extent of damage.
Surface — visible damage

Surface — visible damage

Even at surface level, the parquet flooring shows visible water damage throughout the ground floor living room. This was observable during any site inspection, yet Crawford's initial assessment described only patch repairs as required.

Underneath — rot confirmed

Underneath — rot confirmed

Upon removal of the parquet, the substrate was found to be rotten and saturated with moisture. This level of damage is irreparable by patch repair and requires full replacement — as agreed at the joint site inspection of 29 October 2024. Note: Reception Room 2 does not have underfloor heating; the UFH system is located in the through lounge and kitchen at the rear of the ground floor.

3.4 — Reception Room 2

Parquet Flooring — What Was Not Visible

Key observation: The most significant damage was entirely hidden from view — a non-intrusive inspection could not have identified it.
Damage not visible from surface

Damage not visible from surface

This photograph demonstrates that significant water damage existed behind and beneath the parquet flooring that was entirely invisible from the surface. Crawford's non-intrusive visual inspection — which explicitly stated no floor coverings were lifted — could not have identified this damage.

Removal confirms full extent

Removal confirms full extent

Once the floor was removed, the full extent of water damage became apparent across the entire subfloor area. The damage is widespread and consistent with a sustained escape of water from above, not a localised incident that could be addressed by patch repair.

3.2 — Bedroom 1 (Front)

Bedroom 1 — Cupboard Removal Reveals Ceiling Damage

Key observation: Damage concealed behind fitted furniture was only discovered during rewiring works — demonstrating that visual-only inspections systematically underestimate the true extent of damage.
Cupboard removed — water damage revealed

Cupboard removed — water damage revealed

Removal of a fitted cupboard during rewiring works revealed significant water damage that had been entirely concealed. This damage was invisible during any surface inspection and was not identified in Crawford's assessment. It is directly caused by the escape of water from the 1st floor bathroom above.

Ceiling damage — full removal required

Ceiling damage — full removal required

The extent of water damage to the ceiling structure, revealed only after the cupboard was removed, demonstrates that the ceiling cannot be patched and requires complete replacement. This is consistent with the Schedule of Condition and Works and the RICS-regulated Condition Report prepared by Charles Ramsden Ltd.

3.2 — Bedroom 1 (Front)

Bedroom 1 — Damp Walls Requiring Hacking Off

Key observation: High moisture readings in the walls confirm that damage extends beyond the ceiling — full replastering is required, not cosmetic redecoration.
Damp walls — hacking off required

Damp walls — hacking off required

The walls of Bedroom 1 show significant dampness requiring hacking off and full replastering. Crawford's assessment made no provision for wall replastering in this room. The moisture has penetrated the plaster substrate, meaning surface decoration alone would be insufficient and would fail within months.

Bedroom 2 — new cracks post-incident

Bedroom 2 — new cracks post-incident

In the adjacent Bedroom 2, new cracks appeared in the ceiling and walls following the escape of water. These cracks were not present before the incident and are consistent with structural movement caused by water saturation. The ceiling is fragile and requires full replacement to prevent future failure.

3.5 — Reception Room 1

Reception Room 1 — Floor Damage Pre and Post Strip-Out

Key observation: Damage visible even before strip-out was dismissed by Crawford — removal confirmed the full extent of water penetration into the subfloor.
Damaged floor — Living Room 1

Damaged floor — Living Room 1

The floor of Reception Room 1 shows clear water damage visible from the surface. Tiles have lifted and the flooring substrate shows discolouration consistent with prolonged water exposure. This was identifiable during any site inspection.

Pre-strip-out — cracks and water damage

Pre-strip-out — cracks and water damage

Even before strip-out, visible cracks and water damage to the flooring are clearly evident. The damage extends to the skirtings and wall base. Crawford's assessment did not adequately account for the full scope of floor and skirting replacement required in this room.

3.9 — Downstairs Large Bathroom

Downstairs Large Bathroom — Under-Tile Damage

Key observation: AXA's position that no works are required to the downstairs large bathroom is directly contradicted by photographic evidence of significant dampness and substrate damage beneath the tiles.
Significant damage under tiles

Significant damage under tiles

Removal of floor tiles in the downstairs large bathroom revealed significant damage to the substrate underneath. The substrate shows clear signs of water saturation and structural deterioration. AXA's position that no works are required to this room is not supported by the physical evidence.

Dampness and discolouration confirmed

Dampness and discolouration confirmed

The floor substrate shows extensive dampness and discolouration, indicating prolonged water exposure. The tiles themselves were no longer adhering to the substrate — as shown by the moist, loose tiles — confirming that the damage is not superficial and requires full strip-out and replacement.

3.9 — Downstairs Large Bathroom

Downstairs Bathroom — Corner Dampness

Key observation: Dampness has spread to the walls and corners of the downstairs bathroom, demonstrating the water damage is not confined to the floor.
Corner wall — dampness opposite hallway

Corner wall — dampness opposite hallway

The corner wall of the downstairs large bathroom, directly opposite the hallway, shows significant dampness. This demonstrates that water damage has spread laterally through the structure, affecting the walls as well as the floor. This is consistent with the escape of water having saturated the building fabric over an extended period.

Moist tiles — no longer adhering

Moist tiles — no longer adhering

Floor tiles that were no longer adhering to the substrate confirm that moisture had penetrated beneath the tile bed. Once the tile adhesion fails due to moisture, the entire floor covering must be replaced — patch repair of individual tiles is not a viable or durable solution.

3.7 — Staircase

Staircase — Cracks Revealed After Carpet Removal

Key observation: The staircase cracks were entirely hidden beneath the carpet and could not have been identified by Crawford's visual inspection — they were only discovered during strip-out works.
Stairs after carpet removal — cracks visible

Stairs after carpet removal — cracks visible

Upon removal of the stair carpet, multiple cracks in the stair structure became visible. These cracks were not present before the escape of water and are consistent with water damage causing movement in the timber stair structure. Crawford's visual inspection, conducted with the carpet in place, could not have identified these defects.

Crack detail — staircase

Crack detail — staircase

A close-up view of one of the cracks in the staircase structure. The crack runs through the stair tread and is consistent with water-induced movement rather than normal wear and tear. The staircase requires remedial works to address these structural defects, which were caused by the escape of water.

3.8 — Electrical Installation

Electrical — Rusted Fixtures Confirming Water Damage

Key observation: Physical evidence of rusting to electrical fixtures corroborates both NICEIC EICRs and confirms that water has penetrated the electrical installation, making a full rewire necessary.
Fixtures — severely rusted and damaged

Fixtures — severely rusted and damaged

Electrical fixtures throughout the property show severe rusting and physical damage consistent with prolonged water exposure. Rusted electrical components present a serious safety hazard (C1 — Danger Present) and cannot be remediated by testing alone. Full replacement is required, as confirmed by both independent NICEIC EICRs.

Kitchen — rusted electrical fixtures

Kitchen — rusted electrical fixtures

Kitchen electrical fixtures show the same pattern of severe rusting. The presence of rusting in multiple locations throughout the property confirms that water damage to the electrical installation is widespread, not localised. This is consistent with the findings of both NICEIC EICRs, which rated the installation as 'Unsatisfactory' and recommended a complete rewire.

3.1 — 1st Floor Bathroom

1st Floor Bathroom — Source of Water Damage

Key observation: The 1st floor bathroom is the origin point of the escape of water — damage to the sub-floor structure caused cascading water damage to the rooms below. Note: there is no underfloor heating in this bathroom; underfloor heating is present only in the kitchen and through lounge.
1st floor bathroom — water damage on strip-out

1st floor bathroom — water damage on strip-out

The 1st floor bathroom is the origin of the escape of water. Strip-out reveals severe damage to the softwood sub-floor structure, which has been saturated and requires complete removal. Note: there is no underfloor heating system in this bathroom — the damage is to the structural sub-floor only.

Underfloor — water damage confirmed

Underfloor — water damage confirmed

The sub-floor void of the 1st floor bathroom confirms extensive water damage to the structural softwood elements. Water has penetrated through multiple layers of the floor construction, explaining the widespread damage observed in the rooms below. Full strip-out and replacement of all affected softwood elements is required.

3.0

Supporting Documents

All supporting technical reports, cost schedules, and electrical certificates available for download.

Evidence

Schedule of Condition and Works

4 March 2026 · AV/PV/EVIDENCE/2026-03-04/v1.0

Primary evidence schedule documenting all damage locations, agreed works, and disputed items.

Survey

Condition Report — Charles Ramsden Ltd

May 2024 · LMM/70HR/2024

RICS-regulated flood damage survey by MRICS-qualified surveyor Thomas Chapman. Full room-by-room assessment.

Costs

Original Remedial & Refurbishment Costs

June 2024 · June 2024

Original cost schedule prepared using SPONS rates and measured quantities. Total: £477,227.05 inc. VAT.

Revised Repair Costs — Post AXA Visit

October 2024 · Post Oct 2024

Revised cost schedule following Mr Rutter's site visit, with significant concessions. Total: £329,522.92 inc. VAT.

Independent Contractor Tender — HJ Building & Construction

2024 · HJ/70HR

Independent contractor tender corroborating revised QS figures. Total: £324,998.96 inc. VAT.

AXA Internal Review — Terry McKane-Slaughter (Original Spreadsheet)

12 November 2024 · TMS/AXA/Nov2024

Original building review spreadsheet produced by Terry McKane-Slaughter (AssocRICS) for AXA Insurance. Contains all 54 line items with Terry's comments and accepted figures. Total: £96,500. See /terry-analysis for a full line-by-line comparison against RICS/SPONS market rates.

Electrical

EICR — TM Electrical Engineers

9 July 2025 · 26673 / EICR18.3C

NICEIC Electrical Installation Condition Report. Overall assessment: Unsatisfactory. Full rewire recommended. Multiple C1 and C2 faults identified.

EICR — Niko Electrical Solutions Ltd

7 July 2025 · 31962124 / EICR18.3C

NICEIC Electrical Installation Condition Report. Overall assessment: Unsatisfactory. 20 observations including multiple C1 and C2 faults. Full rewire strongly recommended.

Underfloor Heating Confirmation — Niko Electrical Solutions Ltd

7 July 2025 · U.F.H

Confirmation that water damage burned out the UFH controller and damaged the element. Full replacement required.

RICS

RICS Written Guidance — Order of Cost Assessment Standards

5 December 2025 · RICS/sthompson/Dec2025

Written response from Steven Thompson BSc MBA FRICS, Senior Specialist – Construction, Professional Practice & Development, RICS. Confirms that complex reinstatement cost assessments should be prepared by chartered QSs using recognised market indices (e.g. SPONS), clearly referenced in the report. Forwarded by Martin Windsor MRICS, Charles Ramsden Consultancy.

RICS Written Guidance — Member Qualification & Scope of Work

3 December 2025 · RICS/Fogden/Dec2025

Written response from Fiona Fogden PGLibDip MA, Knowledge and Information Services Manager, RICS. Confirms that reinstatement cost assessments should be prepared in accordance with RICS' Reinstatement Cost Assessment of Buildings, or to appropriate market indices clearly referenced in the report. Addresses the scope of work appropriate for AssocRICS members on complex reinstatement claims.

Cost Analysis & RICS Benchmarks

Full desktop cost analysis benchmarking the repair figures against RICS costmodelling.com and Urbanist Architecture data for Outer London.