Valuation reports are admissible in evidence. Although they are opinion evidence, they nevertheless fall within the category of expert opinion. Sections 68 to 70 of the Evidence Act, 2011 lay down the situations in which the opinion of a person otherwise irrelevant becomes relevant and therefore admissible in judicial proceeding.
Valuation reports are opinion evidence of experts. The provisions of Section 68 Evidence Act, 2011 in dealing with the relevance of the opinion of experts does not contemplate that such opinion would be rendered by a non-natural person or an unidentified person in the guise of a corporate name. NBC Plc. V. Ubani (2009) 3 NWLR (Pt. 1129) 512 CA
As stated before, a valuation report is usually an aspect of opinion evidence specifically expert opinion evidence. In admitting a valuation report, the court would look at the report if it is one made and signed by an identified valuer as a report made by a firm is an inadmissible hearsay where the valuer himself cannot be identified. Furthermore, the valuer must be one who is capable of being called as a witness when the authenticity of the report is in dispute. Where however he cannot be called as a witness proper foundation must be given to the satisfaction of the court why he could not be procured as a witness. NBC Plc. V. Ubani (2009) 3 NWLR (Pt. 1129) 512 CA.
A valuation report given by an expert and admitted in court as a piece of evidence without any contradiction does not make it inevitably acceptable by the court simply because it was uncontroverted. The court would only accept such evidence only if there is no good reason to reject and in the process of scrutinizing it, same could be rejected if there is a reason to do so. J.E. Elukpo & Sons Ltd. V. F.H.A (1991) 3 NWLR (Pt. 179) 322 (at 334).