Home Surveys - Lessons from Fryer v Bunney and the Accountability Gap

Buying a home is a big, expensive deal. When something goes wrong, the financial loss can be devastating - and the emotional toll is just as real. A home survey should reduce that risk. Surveyors are there to inspect, record, and report honestly on the condition of a property. But when survey reports are poor, when site notes are vague, or when damp meter readings aren’t properly recorded, consumers suffer and surveyors are left exposed.

Why the Home Survey Standard matters

This is why the RICS Home Survey Standard (HSS), currently under consultation, matters. It is the framework against which RICS regulates its members. Yet the consultation highlights a tension at the heart of our profession: consumers and surveyors expect accountability, courts demand thoroughness, but regulation can end up policing compliance with minimum rules rather than the higher standards set out in case law.

Fryer v Bunney – a lesson in thoroughness

The case of Fryer v Bunney [1982] ORC still echoes in surveying practice today. The surveyor was found negligent after failing to discover considerable damp at 5 Cherry Way, Daw’s Hill, Essex.

Although his survey report stated that a Protimeter had been used, there were no records of damp meter readings for parts of the house. Expert witnesses — including a plumber, a chartered engineer, and two chartered surveyors — demonstrated that if sufficiently extensive readings had been taken, the damp would have been revealed.

Mr Justice Newey was sympathetic, making clear that this was not a case of deliberate corner-cutting. Instead, he described it as the danger of routine: a man doing a standard job too frequently, and not applying the necessary thoroughness on that day.

The lesson was, and still is, unmistakable: surveyors must not only use the right tools, but apply them methodically and record their results clearly. Good intentions are no defence if the evidence is missing and the client suffers loss.

The accountability gap

This case also highlights what I call the accountability gap. Consumers often struggle to get redress when survey reports fall short, and surveyors can face catastrophic claims without clear processes to resolve issues earlier.

Part of the problem lies in how the Home Survey Standard is used. If it is too light-touch, RICS has little to enforce beyond the bare minimum, leaving consumers unprotected and surveyors without clear benchmarks. Yet if the standard is too prescriptive, surveyors risk being reduced to box-tickers, unable to apply professional judgement to the unique circumstances of each property.

Take measurements as an example. Some surveyors argue it isn’t always necessary, while others see it as essential. The lack of clear guidance leaves consumers uncertain and surveyors exposed. What’s really needed is not just clarity around survey levels, but around survey services — with explicit guidance on when certain tasks (like taking property measurements) are expected, and when it is acceptable not to.

This would bridge the gap between best practice and the changing reality of the way we work today, giving RICS clearer ground for regulation and giving surveyors more confidence that they are meeting an appropriate professional standard.

Why stronger records are the answer

The common thread across all these forums is evidence. Without photographs, clear survey site notes, and properly recorded measurements and meter readings, surveyors are left exposed and consumers are left without answers.

In 2025, there is no excuse for poor records or reports that do not help defend a complaint, and consumers cannot understand. Digital tools make it simple to capture structured notes and photographs. And in an age where AI can manipulate data and images, a reliable contemporaneous record of truth has never been more important. Consumers need to trust their surveyor, and surveyors need protection from unfair complaints.

Some worry that requiring more structured notes or photographs will add cost and complexity, pricing some buyers out of surveys. But the extra time is minimal compared to the protection gained. Stronger records reduce disputes, saving time, money, and reputational damage for everyone.

What the HSS consultation must deliver

The consultation is a chance to raise the bar. The Home Survey Standard should require structured, legible site notes, make photographs in all reports standard practice, and require surveyors to record how and where damp and other risks were tested.

The danger, however, is trying to squeeze everything into the HSS. Being overly prescriptive is not the answer. A review of how members are regulated and how complaints are handled by RICS must run alongside the HSS review, or nothing will truly change.

Why It Matters

Fryer v Bunney taught us decades ago that poor records cost surveyors dearly. Unless the HSS is strengthened — and supported by a robust regulatory approach — the gap between regulation, redress, and case law will continue, leaving consumers frustrated and surveyors exposed.

Closing the accountability gap isn’t about blame. It’s about ensuring the HSS is prescriptive enough for RICS to regulate effectively, while still empowering surveyors to apply professional judgement. That’s the only way to build fairness, clarity, and trust in our profession.

A Personal Note

These thoughts come from my experience of over 20 years in surveying and supporting both consumers and surveyors. They’re simply my perspective - shared to open up discussion and encourage more voices to feed into the consultation. If you have a view, please take a moment to respond - your input really does make a difference. This is the link to the consultation.

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