What is the common law duty of care to avoid causing pure economic loss?

In general, the common law has been reluctant to find a duty of care to avoid causing foreseeable pure economic loss, largely for policy reasons. By definition, such losses are not the direct result of the defendant’s action. It has been argued that imposition of liability for causing pure economic loss risks exposing the defendant to indeterminate liability (“liability in an indeterminate amount for an indeterminate time to an indeterminate class”) and, in a competitive commercial environment, may be “inconsistent with community standards in relation to what is ordinarily legitimate in the pursuit of personal advantage.” (Perre v. Apand Pty. Ltd. (1999), 164 A.L.R. 606 (H.C.A.) per Gaudron J. at paras. 32-33.) Exceptions have been where the courts have found a special relationship, or proximity, such as the cases of negligent misstatement, where it can be shown that the defendant claimed special skill or knowledge and the plaintiff, to the defendant’s knowledge, relied on the statement or professional negligence.