AV/PV/EVIDENCE/2026-03-04/v1.0
Water Damage Evidence
70 High Road, Buckhurst Hill
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, floor plans, cost assessments, and supporting technical reports, organised by location.
Insureds
Mr & Mrs Verma
Insurer
AXA Insurance
Claim Reference
12648569H
Date of Loss
January 2024
Key Facts at a Glance
The following five facts provide the essential context for this evidence bundle. They are presented here for ease of reference before the detailed evidence sections that follow.
Date of Loss
January 2024
Escape of water from the first floor bathroom. Damage spread to multiple rooms across both floors.
Scope of Damage
8 locations affected
Both floors affected: 1st floor bathroom (source), Bedrooms 1–2, Stairs, Reception 1 & 2, Large Bathroom, Electrical installation throughout.
Joint Inspection — 29 Oct 2024
5 items agreed by AXA
Mr N. Rutter (AXA) agreed on site: full rewire, parquet flooring replacement, underfloor heating replacement, staircase carpet, kitchen works. Two rooms were not inspected: Reception 1 and the Large Bathroom.
Subsequent Schedule
Items not carried forward
Crawford & Company's subsequent schedule did not reflect a number of the items agreed at the joint inspection. No written explanation was provided for the differences. AXA's settlement position was based on this schedule.
Cost Gap
£329,523 vs £109,920
The claimant's revised figure (post-concessions, SPONS-rated, MRICS-prepared, corroborated by independent tender) is £329,523. The insurer's counter-assessment is £109,920 — prepared without referenced market indices by an Associate Member who has since left the firm.
Note: Facts 03 and 04 are of particular relevance to the independent expert's assessment. The full documentary record supporting each fact — including the Schedule of Condition and Works, cost schedules, EICRs, and RICS correspondence — is available in Section 6.0 (Documents).
Overview
Note to the Independent Expert
This evidence bundle has been compiled to assist your independent assessment. It is organised by location, with photographic and video evidence, floor plans, and supporting cost assessments available throughout. All documents referenced are available for download in Section 6.0. The independent expert is invited to form their own professional opinion based on the evidence presented.
In January 2024, a burst pipe in the loft area of 70 High Road caused an escape of water that cascaded through multiple levels of the property, resulting in damage to ceilings, walls, flooring, electrical installations, and mechanical services. The property has been unoccupied since the incident.
AXA Insurance appointed Crawford & Company as loss adjusters. A joint site inspection was subsequently conducted on 29 October 2024 by Mr Nicholas Rutter of Ruxley Chartered Surveyors on behalf of AXA. The scope of works agreed at that inspection, and the position taken in AXA's subsequent written assessment, are set out in Section 2.0 below.
Items — Change in Position
3
Items noted as agreed at the joint inspection (29 Oct 2024) — position subsequently revised in writing
Independent Reports
2
NICEIC-certified EICRs both rated the installation Unsatisfactory
Difference in Cost Assessments
£285k
Difference between the independently prepared cost assessment and the insurer's counter assessment
RICS Guidance — Professional Standards for Cost Assessments
RICS Senior Specialist Steven Thompson BSc MBA FRICS confirmed in writing (December 2025) that 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," and that reinstatement cost assessments should reference recognised market indices, which should be clearly referenced in the report. The insurer's counter assessment was prepared by Mr Terry McKane-Slaughter (AssocRICS). No market indices are referenced in that assessment.
Technical Note — Concealed Water Damage
Water damage resulting from an escape of water incident is frequently concealed beneath surface finishes — including floor tiles, floor coverings, wall plaster, and ceiling linings — and cannot be identified or quantified by visual inspection alone. The full extent of damage only becomes apparent once strip-out works are undertaken and surface finishes are removed.
This is directly relevant to the assessments carried out at this property. Crawford & Company's initial budget estimate of £10,000–£15,000 was explicitly prepared on the basis of a non-intrusive, visual-only inspection with no surfaces lifted. The photographic and video evidence in Section 3.0 demonstrates the extent of damage that was revealed only upon strip-out, including:
- Reception Room 2 (Parquet Flooring): Significant rot and dampness beneath the parquet surface, not visible from above
- Downstairs Large Bathroom: Moisture and dampness beneath floor and wall tiles, causing tiles to loosen and detach
- 1st Floor Bathroom: Severe water damage to softwood structures beneath the floor surface
- Bedroom 1: Significant water damage and cracking concealed behind a fitted cupboard
- Staircase: New cracks in the stair structure revealed only after carpet removal
Note on Additional Findings — Downstairs Large Bathroom & Reception Room 1
The Downstairs Large Bathroom and Reception Room 1 were omitted from the scope of the joint site inspection of 29 October 2024. It is acknowledged that these areas were not assessed at that meeting and therefore do not form part of the agreed scope. However, the claimant submits that their omission from the joint inspection does not extinguish the insurer's liability for damage that is directly causally linked to the escape of water incident.
The photographic and video evidence for both areas (Sections 3.5 and 3.9) demonstrates damage that is consistent in character and causation with the damage confirmed in the areas that were inspected. The independent expert is invited to consider whether the damage in these areas is causally connected to the incident and whether it falls within the scope of the policy. The claimant reserves the right to rely on this evidence in full.
Statement on Betterment — Full Refurbishment at Own Cost
Where any element of the remedial works results in an improvement beyond the pre-loss condition of the property, the claimant confirms that the cost of any such betterment has been, and will continue to be, met entirely at the claimant's own expense. The claim is limited to the reasonable cost of reinstating the property to its pre-loss condition. No element of betterment is included in the figures presented in this evidence bundle.
Key Disputed Items
The following table summarises the key items of work, the position of Crawford & Company, the position noted at the joint site inspection on 29 October 2024, and the position taken in AXA's subsequent written assessment.
Areas Not Inspected at Joint Site Inspection — 29 October 2024
The following two areas were omitted from the scope of the joint site inspection of 29 October 2024 and are therefore not reflected in the table below. Photographic and video evidence for both areas is available in Section 3.0:
- 1.Downstairs Large Bathroom (Ground Floor) — Significant dampness and water damage found beneath floor and wall tiles upon strip-out. Tiles were found to have loosened due to moisture ingress. See Section 3.9 for photographic and video evidence.
- 2.Reception Room 1 — Living Room 1 (Ground Floor) — Cracking, dampness, damaged skirtings and flooring consistent with the escape of water incident. Visible damage was present prior to strip-out. See Section 3.5 for photographic and video evidence.
| Item | Crawford Position | Mr Rutter — 29 Oct 2024 | AXA Final Position | Status |
|---|---|---|---|---|
| Full Rewire | Partial rewire only | Complete rewire agreed | Partial rewire | Position Revised |
| Underfloor Heating Replacement | Further evidence required | Complete replacement agreed | Testing only | Position Revised |
| Reception Room 2 — Parquet Flooring | Not required | Replacement agreed on site | Not required (retracted in Excel) | Position Revised |
| Downstairs Large Bathroom | Not required | Recorded as not required | Not required | Disputed |
| Roof Trusses | Not required | Not required | Not required | Confirmed |
The scope of works noted as agreed at the joint inspection of 29 October 2024, and the position set out in AXA's subsequent written assessment, are shown above for reference. The independent expert is invited to assess the condition of each area based on the photographic and video evidence in Section 3.0.
Photographic & Video Evidence by Location
The following sections provide contemporaneous photographic and video evidence taken during strip-out works, organised by location. Each section includes a summary of the positions recorded at the joint inspection and the condition found. Click any image to enlarge, or any video to play. Areas marked Omitted from scope — 29 Oct 2024 were not covered at the joint site inspection.
Property Floor Plans — Spatial Reference
The floor plans below identify the layout of the property. Rooms referenced in the evidence sections below correspond to the locations shown. The areas highlighted in the evidence sections can be cross-referenced against these plans to understand the spatial extent of the damage.
Ground Floor Plan
Reception 1 & 2 · Kitchen · Bathroom · Cloakroom · Passage
First Floor Plan
Bedrooms 1–4 · Family Bathroom · Landing
Crawford & Co. Position
Partial remedial works only
Mr Rutter (AXA Surveyor) — 29 Oct 2024
Agreed — full strip-out required (29 Oct 2024)
Actual Condition Found
Severe water damage to all softwood structures confirmed upon strip-out. Full removal required.
Photographic Evidence (2 images)
Video Evidence (1 video)
Crawford & Co. Position
Ceiling repairs to affected area only
Mr Rutter (AXA Surveyor) — 29 Oct 2024
Ceiling repairable — full replacement not required
Actual Condition Found
Significant water damage and structural cracking revealed behind cupboard. Damp walls requiring hacking off and replastering.
Photographic Evidence (3 images)
Crawford & Co. Position
Isolated damp treatment only
Mr Rutter (AXA Surveyor) — 29 Oct 2024
Ceiling fragile — further investigation required
Actual Condition Found
New post-incident cracks confirmed. Fragile ceiling requiring full replacement.
Photographic Evidence (2 images)
Crawford & Co. Position
Not required — only patch repairs
Mr Rutter (AXA Surveyor) — 29 Oct 2024
AGREED on site (29 Oct 2024) — full replacement required. Subsequently retracted.
Actual Condition Found
Significant water damage, dampness and rot confirmed beneath parquet. Full replacement necessary.
Photographic Evidence (6 images)
Cross-Reference — Good Faith Conduct (Section 7.0)
The parquet flooring replacement was one of five items agreed at the joint site inspection of 29 October 2024. The video evidence above shows the condition of the parquet surface prior to strip-out, and the rotted subfloor revealed upon removal. This item did not appear in Crawford & Company's subsequent schedule. The full record of the on-site agreements and the subsequent schedule is documented in Section 7.0 (Good Faith Conduct).
Video Evidence (5 videos)
Crawford & Co. Position
Connection to incident questioned — not attributed
Mr Rutter (AXA Surveyor) — 29 Oct 2024
Omitted from scope at joint site visit (29 Oct 2024)
Actual Condition Found
Cracking, dampness, damaged skirtings and flooring confirmed. Hardboard flooring found to be breaking upon strip-out. Water damage consistent with escape of water incident.
Photographic Evidence (7 images)
Video Evidence (1 video)
Crawford & Co. Position
Not identified during inspection
Mr Rutter (AXA Surveyor) — 29 Oct 2024
Cracks noted — consistent with water damage
Actual Condition Found
Multiple new cracks in stair structure confirmed after carpet removal. Water damage to stair timbers. Staircase subsequently replaced in full.
Photographic Evidence (4 images)
Video Evidence (1 video)
Crawford & Co. Position
Partial rewire only — test required
Mr Rutter (AXA Surveyor) — 29 Oct 2024
AGREED on site (29 Oct 2024) — complete rewire required
Actual Condition Found
Both NICEIC EICRs rated 'Unsatisfactory'. Multiple C1 (Danger Present) and C2 (Potentially Dangerous) faults. Full rewire mandatory. UFH controller burned out — full replacement required, including removal of kitchen and through lounge flooring to access the system.
Photographic Evidence (2 images)
Crawford & Co. Position
Not required
Mr Rutter (AXA Surveyor) — 29 Oct 2024
Not inspected at joint site visit (29 Oct 2024)
Actual Condition Found
Significant dampness and water damage confirmed to substrate when tiles lifted. Full strip-out and replacement required.
Photographic Evidence (4 images)
Video Evidence (2 videos)
Photo Comparisons with Commentary
Each comparison below presents two photographs from the same location, with expert commentary explaining what each image demonstrates. These comparisons are designed to show that the damage is significant, that it was not visible during surface-only inspections, and that the scope of works claimed is fully justified.
Showing 10 comparisons
Reception Room 2
Parquet Flooring — Surface vs. Underneath
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
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
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.
Click any image to enlarge
parquet-surface-vs-underneath
Reception Room 2
Parquet Flooring — What Was Not Visible
The most significant damage was entirely hidden from view — a non-intrusive inspection could not have identified it.
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
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.
Click any image to enlarge
parquet-hidden-damage
Bedroom 1 (Front)
Bedroom 1 — Cupboard Removal Reveals Ceiling Damage
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
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
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 Lancaster Maloney Martin Ltd.
Click any image to enlarge
bedroom1-cupboard-ceiling
Bedroom 1 (Front)
Bedroom 1 — Damp Walls Requiring Hacking Off
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
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
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.
Click any image to enlarge
bedroom1-damp-walls
Reception Room 1
Reception Room 1 — Floor Damage Pre and Post Strip-Out
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
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
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.
Click any image to enlarge
reception1-floor-damage
Downstairs Large Bathroom
Downstairs Large Bathroom — Under-Tile Damage
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
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
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.
Click any image to enlarge
large-bathroom-tiles
Downstairs Large Bathroom
Downstairs Bathroom — Corner Dampness
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
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
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.
Click any image to enlarge
bathroom-corner-dampness
Staircase
Staircase — Cracks Revealed After Carpet Removal
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
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
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.
Click any image to enlarge
stairs-cracks
Electrical Installation
Electrical — Rusted Fixtures Confirming Water Damage
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
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 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.
Click any image to enlarge
electrical-rust
1st Floor Bathroom
1st Floor Bathroom — Source of Water Damage
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
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
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.
Click any image to enlarge
1st-floor-bathroom-underfloor
Cost Comparison
The following table compares the claimant's independently prepared and evidenced costs against the insurer's counter assessments. The claimant's figures are based on SPONS rates and measured quantities, prepared by MRICS-qualified professionals and corroborated by an independent contractor tender.
Original Claim (June 2024)
Lancaster Maloney Martin Ltd
Revised Claim — Post AXA Visit
Lancaster Maloney Martin Ltd
Independent Contractor Tender
HJ Building & Construction Ltd
AXA Internal Review (Nov 2024)
Terry McKane-Slaughter
Crawford Draft Schedule
Jason Williams MRICS, Crawford & Co.
Crawford Initial Budget Estimate
Liam Shakespeare, Crawford Building Consultancy
| Source | Prepared By | Basis | Total (exc. VAT) | Total (inc. VAT) | Notes |
|---|---|---|---|---|---|
Original Claim (June 2024) | Lancaster Maloney Martin Ltd (MRICS) | SPONS rates, measured quantities | £397,689.21 | £477,227.05 | Full scope including roof trusses, all doors, large bathroom, complete ceiling replacement |
Revised Claim — Post AXA Visit | Lancaster Maloney Martin Ltd (MRICS) | SPONS rates, measured quantities — concessions made | £274,602.43 | £329,522.92 | Significant concessions made following Mr Rutter's site visit. Roof trusses, large bathroom, softwood flooring omitted. |
Independent Contractor Tender | HJ Building & Construction Ltd | Market rates — independent tender | £270,832.46 | £324,998.96 | Independent contractor tender closely corroborates revised QS figures, validating accuracy. |
AXA Internal Review (Nov 2024) | Terry McKane-Slaughter (AssocRICS) | Provisional sums — no SPONS rates referenced | £91,600 | £109,920 | Prepared by AssocRICS (not a Chartered QS). No market indices referenced. RICS confirmed this does not meet reinstatement cost assessment standards. |
Crawford Draft Schedule | Jason Williams MRICS, Crawford & Co. | Largely unpriced — most items at £0 | £33,075 | £39,690 | Crawford's own schedule is largely unpriced. Plastering, decoration, brickwork and general works all priced at £0. |
Crawford Initial Budget Estimate | Liam Shakespeare, Crawford Building Consultancy | Non-intrusive visual inspection only — no surfaces lifted | £12,500 | £15,000 | Based on visual-only inspection. No floor coverings or surfaces lifted. Explicitly stated as a budget estimate only. |
Validity of AXA's Counter Assessment
AXA's counter assessment was prepared by an AssocRICS member, not a Chartered Quantity Surveyor. RICS has confirmed in writing that such assessments must be prepared by appropriately competent professionals and must reference recognised market indices (e.g. SPONS). Crawford's assessment referenced no market indices. The Associate Member has since left Crawford & Company.
Full Desktop Analysis
Desktop Cost Analysis Report
A comprehensive desktop analysis using RICS costmodelling.com and Urbanist Architecture benchmarks, demonstrating that the claimant's revised costs are consistent with — and conservative against — current Outer London market rates.
Document Library
All documents referenced in this evidence bundle are available below, organised by category. Each document can be opened in a new tab or downloaded directly.
1
Evidence & Schedules
1
Survey Reports
3
Cost Assessments
3
Electrical Reports
Evidence & Schedules
Survey Reports
Cost Assessments
Electrical Reports
Both EICRs below were conducted independently by separate NICEIC-certified contractors. Both returned an overall classification of Unsatisfactory with multiple C1 (Danger Present) and C2 (Potentially Dangerous) observations under BS 7671. This convergence of two independent assessments is directly relevant to the scope of electrical works required.
RICS Professional Correspondence
RICS Knowledge & Information Services
Email correspondence — December 2025
Correspondence with RICS Senior Specialist — Steven Thompson BSc MBA FRICS
Email exchange between the claimant's Chartered Quantity Surveyor (Martin Windsor MRICS, Charles Ramsden) and RICS Senior Specialist Steven Thompson BSc MBA FRICS, confirming that:
- Reinstatement cost assessments must be prepared by appropriately competent professionals — ideally Chartered Quantity Surveyors.
- Cost assessments must reference recognised market indices (e.g. SPONS), which must be clearly stated in the report.
- The insurer's counter assessment was prepared by an AssocRICS member registered as a Valuer, not a Chartered QS, and references no market indices.
- The Associate Member who prepared the counter assessment has since left Crawford & Company.
Extract — Steven Thompson FRICS (RICS Senior Specialist)
"You should be making clear that 'your' estimate has been prepared by someone who is suitably qualified to do so, whereas the 'other estimate' might have been prepared by someone not so."
Extract — RICS Knowledge & Information Services Manager
"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."
Claimant's QS Correspondence — Charles Ramsden
Martin Windsor MRICS (Charles Ramsden) — Formal Correspondence to Crawford & Company
Chartered Quantity Surveyor · Basis of Original Costing & Request for Clarification
The following is the formal written correspondence from Martin Windsor MRICS of Charles Ramsden (Chartered Quantity Surveyors) to Crawford & Company, clarifying the basis of the original costing and requesting clarification of the basis on which Crawford's counter-assessment was prepared.
We refer to your recent correspondence and would like to clarify the basis of the original costing provided by Charles Ramsden.
The original costings were prepared using the information available at the time and were explicitly based on the findings and assumptions contained within the Lancaster Maloney Martin condition survey dated May 2024. As such, the pricing reflected the scope, risks, and extent of work identified in that survey.
As you are aware, a meeting took place with all parties on site on 29 October 2024, and the original Charles Ramsden costs were used as the basis of the meeting, as nobody recognised the document produced by Crawford's. During this site visit, it was noted that some conditions and scope identified in the original condition survey had changed, and an amended costing was issued by Charles Ramsden to reflect this meeting.
As previously requested, we would be grateful if you could confirm the basis on which Crawford's document was prepared. In particular, please clarify what information, inspections, reports, or assumptions were relied upon in compiling this document.
Additionally, we would welcome clarification as to how a property that has suffered water damage can be "partially re-wired." Given the nature of water ingress and its potential impact on electrical systems, it would be helpful to understand what assessments were undertaken, what elements were excluded, and how compliance and safety have been ensured.
This information is required in order for us to fully understand the scope and rationale behind the proposals put forward.
Kind regards,
Martin Windsor MRICS
Charles Ramsden, Chartered Quantity Surveyors
Note: This document will be updated when the final signed version is available.
Good Faith Conduct
This section sets out the chronological record of the joint site inspection of 29 October 2024, the items agreed on that date, and the subsequent discrepancy between those agreements and the schedule later produced by Crawford & Company. Mr Rutter conducted the inspection professionally and the agreements reached on site are not in dispute. The question is whether those agreements were accurately reflected in the subsequent schedule.
An escape of water incident occurred at 70 High Road, Buckhurst Hill, Essex IG9 5RW. The claimant notified AXA Insurance and a claim was registered under reference 12648569H.
An independent RICS-regulated condition report was commissioned from Lancaster Maloney Martin Ltd (Thomas Chapman MRICS). The report documented widespread water damage across all floors, confirmed the need for a full rewire, and identified damage to flooring, ceilings, walls, and bathroom substrates throughout the property.
A full cost schedule was prepared by Martin Windsor MRICS (Charles Ramsden, Chartered Quantity Surveyors) using measured quantities and SPONS rates. The schedule covered all areas of damage identified in the condition report. Total: £477,227.05 inc. VAT.
Joint Site Inspection — Agreements Reached
29 October 2024 · Nicholas Rutter (AXA Insurance Surveyor) · Witnessed by Paul Garratt (Edge Consulting)
A joint site inspection was conducted at the property with Nicholas Rutter, AXA Insurance's appointed surveyor. Mr Rutter carried out a thorough inspection of the property and, following that inspection, the following items were agreed on site. The agreements were independently witnessed by Paul Garratt of Edge Consulting, who was present throughout the inspection.
Full rewire of the electrical installation
Agreed on site following inspection
Replacement of underfloor heating system
Agreed on site following inspection
Replacement of parquet flooring in Reception Room 2
Agreed on site — rot and dampness confirmed
Replacement of kitchen
Agreed on site following inspection
Replacement of staircase carpet
Agreed on site following inspection
In recognition of the agreements reached, the claimant voluntarily revised the cost schedule downward, removing items not agreed (including roof trusses, large bathroom, and softwood flooring). The revised total was £329,522.92 inc. VAT — a reduction of £147,704.13 (31%) from the original claim.
The claimant formally notified AXA Insurance, via Suzy Brown, of the commencement of remedial works at the property in January 2025. This notification was provided in advance of works commencing, in accordance with the claimant's obligations under the policy. All works undertaken were necessary remedial works arising directly from the escape of water incident.
Crawford's Schedule — Agreed Items Omitted
Post October 2024 · Crawford & Company Loss Adjusters
Following the joint inspection, Crawford & Company produced a revised schedule of works. That schedule did not reflect a number of the items agreed at the joint inspection. No written explanation was provided for the differences. The items not carried forward included:
Full rewire
Agreed at Joint Inspection
Agreed at joint inspection — 29 Oct 2024
Crawford's Subsequent Position
Reverted to partial rewire only
Underfloor heating replacement
Agreed at Joint Inspection
Agreed at joint inspection — 29 Oct 2024
Crawford's Subsequent Position
Reduced to testing only
Parquet flooring replacement (Reception Room 2)
Agreed at Joint Inspection
Agreed at joint inspection — 29 Oct 2024
Crawford's Subsequent Position
Removed from schedule
No written explanation was provided by Crawford & Company for the differences between the on-site agreements and the subsequent schedule. AXA Insurance subsequently relied on Crawford's revised schedule as the basis for their settlement position.
AXA's internal review, prepared by Terry McKane-Slaughter (AssocRICS) — an Associate Member registered as a Valuer — produced a cost assessment of approximately £91,600 ex-VAT. This assessment accepted some items agreed by Mr Rutter (parquet flooring, kitchen, staircase carpet, UFH testing) but rejected new ceilings, new doors, bathrooms, and the majority of remedial works. It contained no reference to SPONS or any recognised market index.
Following the impasse, the claimant's Chartered Quantity Surveyor (Martin Windsor MRICS, Charles Ramsden) sought guidance from RICS. RICS Senior Specialist Steven Thompson BSc MBA FRICS confirmed in writing that reinstatement cost assessments must be prepared by appropriately competent professionals and must reference recognised market indices. The insurer's counter assessment references no such indices. Full correspondence is available in Section 6.0.
Summary of Position
The claimant has at all times engaged constructively with the insurer's process. A voluntary reduction of £147,704 (31%) was made following the joint inspection, reflecting the agreements reached on site. The revised figure of £329,522.92 remains below the RICS lower quartile benchmark for a property of this size and specification in Outer London, and is independently corroborated by a contractor tender within 1.4%.
The independent expert is invited to consider the full sequence of events set out above when forming their assessment, and in particular to note that the items now in dispute were agreed at the joint site inspection. Mr Rutter's inspection and the agreements reached on that date are not challenged. The question for the independent expert is whether the scope of works required to reinstate the property is accurately reflected in the subsequent schedule.
Expert's Note on Methodology
The following observations are provided to assist the independent expert in contextualising the evidence presented in this bundle. They are offered as professional reference points, not as instructions or submissions.
1. Adequacy of Visual-Only Inspections for Escape of Water Claims
It is well-established in building surveying practice that a visual-only, non-intrusive inspection is insufficient to determine the full extent of damage following an escape of water incident. Water migrates through structural elements, accumulates beneath floor finishes, and causes progressive deterioration to substrates, joists, and wall linings that is not visible at the surface.
Crawford & Company's initial budget estimate of £10,000–£15,000 was prepared on the basis of a non-intrusive visual inspection with no surfaces lifted. This is explicitly acknowledged in their report. The photographic evidence in Section 3.0 demonstrates the extent of damage that was only revealed upon strip-out — including rotted parquet substrate, loosened bathroom tiles, softwood deterioration, and structural cracking concealed beneath carpet. A cost assessment prepared without intrusive investigation cannot be considered a reliable basis for settlement in a claim of this nature.
2. Electrical Installation — Interpretation of Dual Unsatisfactory EICRs
Two independent NICEIC-certified Electrical Installation Condition Reports (EICRs) were commissioned from separate contractors. Both returned an overall classification of Unsatisfactory, with multiple C1 (Danger Present) and C2 (Potentially Dangerous) observations. Under BS 7671 (IET Wiring Regulations), a C1 observation requires immediate remedial action.
The convergence of two independent NICEIC assessments on the same overall classification and fault categories is significant. It is not consistent with a partial rewire position. The independent expert is invited to review both EICRs in full, available in Section 6.0. The underfloor heating system was also confirmed by a NICEIC-certified engineer as having failed due to water damage, with the controller burned out and the element damaged.
3. Cost Assessment Methodology — SPONS vs. Provisional Sums
The claimant's cost assessments were prepared by a MRICS-qualified Chartered Quantity Surveyor using measured quantities and SPONS (Spon's Architects' and Builders' Price Book) rates — the recognised industry-standard reference for UK construction cost estimating. The revised assessment of £329,522.92 (inc. VAT) was independently corroborated by a contractor tender from HJ Building & Construction Ltd at £324,998.96 (inc. VAT), a variance of less than 1.4%.
The insurer's counter assessment was prepared using provisional sums with no reference to SPONS or any other recognised market index. RICS Senior Specialist Steven Thompson BSc MBA FRICS confirmed in writing (December 2025) that reinstatement cost assessments must reference recognised market indices, which should be clearly referenced in the report. No such reference appears in the insurer's assessment.
The Desktop Cost Analysis Report (accessible from Section 5.0) benchmarks the claimant's revised figure against RICS costmodelling.com data and Urbanist Architecture's published London refurbishment rates. The revised claim of £329,522.92 sits below the RICS lower quartile benchmark for a property of this size and specification in Outer London.
4. Areas Not Inspected at the Joint Site Inspection — 29 October 2024
Two areas of the property were not inspected during the joint site inspection of 29 October 2024: the Downstairs Large Bathroom and Reception Room 1 (Living Room 1). As a result, no agreed position exists for these areas, and they are not reflected in the insurer's subsequent written assessment.
The photographic and video evidence for both areas (Section 3.5 and Section 3.9) demonstrates conditions that are consistent with the escape of water incident. The independent expert is invited to inspect both areas and form their own assessment of the works required. These areas represent a material component of the overall repair scope that has not yet been subject to independent professional review.
5. Good Faith Conduct — Voluntary Reduction of Claim
Following the joint site inspection of 29 October 2024, the claimant voluntarily revised their cost assessment downward from £477,227.05 to £329,522.92 — a reduction of £147,704.13 (31%). This revision excluded roof trusses, the large bathroom, softwood flooring, and a number of other items as concessions made in good faith following the joint inspection.
The revised figure was subsequently not accepted by the insurer. The independent expert is invited to consider whether the scope of works reflected in the revised assessment — which sits below the RICS lower quartile benchmark — represents a reasonable and proportionate response to the damage documented in this bundle.
The observations above are provided for professional reference only. The independent expert is invited to form their own opinion based on their inspection of the property and review of the evidence presented in this bundle. All supporting documents are available for download in Section 6.0.