In Potts v. Miller (1940), 64 C.L.R. 282 (H.C.), the question was whether a purchaser induced to buy by a fraud may seek compensation for all loss in fact suffered by virtue of the transaction. Citing venerable English authority, Dixon J. says (at p. 298) that "if, after the date of purchase, the thing which the plaintiff was induced to buy loses in value owing to accidental or extrinsic causes, that loss is not the reasonable consequence of the inducement". And later: "If the cause be 'independent,' 'extrinsic,' 'supervening,' or 'accidental,' then the additional loss is not the consequence of the inducement". That being so, it must, I think, follow that independent or extrinsic events causing increase in value after the date of sale likewise are not to be taken into consideration in assessment of damages for fraudulent misrepresentation inducing a transaction.
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