Multiplex 324 Queen Street Landowner Pty Ltd v Department of Natural Resources, Mines and Water

Multiplex 324 Queen Street Landowner Pty Ltd brought an appeal against the Department of Natural Resources, Mines and Water, challenging the valuation of certain lots at 324 Queen Street. The dispute centred on the determination of the unimproved value of improved commercial land in the CBD, with the valuation being conducted under the Valuation of Land Act 1944. The Queensland Court of Appeal was tasked with resolving the conflict between the parties.

The court had to determine whether the Chief Executive's method of valuing the unimproved value of the improved land was legally sound and whether the sales used in the valuation analysis were appropriate and comparable. The key issue was whether the method of valuation used by the Chief Executive was in accordance with the Act, particularly in relation to the use of sales data and the comparability of sales for different purposes.

In delivering the judgment, the Court of Appeal found that the Chief Executive's valuation did not comply with the statutory requirements. The court held that the Chief Executive had not properly considered the highest and best use of the land and had failed to adequately analyse the sales data used in the valuation. The court emphasised the importance of ensuring that the sales used in the valuation were comparable and suitable for the purpose of determining the unimproved value of the land. Consequently, the Court of Appeal set aside the Chief Executive's valuation and determined the unimproved value of the lots at $8,200,000.