Professional Negligence under Tort Law

Greetings Tutor I hope your are doing well. I have some doubt related the following question that relates to usage of Exclusion Clause under Professional Negligence.

Scenario – Oliver was selling his inn, the Cromwell Arms, and Charles was considering buying it. Charles wrote to Oliver’s accountant, Richard, and requested information about the annual turnover of the inn. The accountant wrote to Charles informing him that the inn’s annual sales were ‘in the region of £200,000’, adding that the information was given without any responsibility on his part.

Charles purchased the inn and subsequently found that although several years previously turnover had once approached £200,000, generally it was about £150,000 a year.

Question –
Which of the following TWO statements are correct?

a) The accountant owes a duty of care to Charles
b) The accountant does not owe a duty of care to Charles
c) The accountant will be liable for the losses which Charles has suffered
d) The accountant will not be liable for the losses which Charles has suffered

Ans – The accountant owes a duty of care to Charles and The accountant will be liable for the losses which Charles has suffered.

My Question,
As per the, Case Law of

1) Hedley Byrne & Co Ltd v Heller and Partners Ltd 1963. Heller and Partners Ltd were able to avoid the liability for professional negligence because of the Disclaimer.

2) Hercules Mgmt. Ltd. v. Ernst & Young (SCC)

? Reasonable foreseeability

More likely if
a) defendant claimed special knowledge
b) statement communicated on serious occasion
c) statement made in response to inquiry
d) Defendant received financial benefit
e) statement of fact or an opinion or prediction based on fact, rather than a pure

•) Less likely if the Statement is accompanied by a Disclaimer

3) As per ACCA in one of its Article
Furthermore, it had become a common practice among the Auditor
to include “Disclaimer of Liability” to the third parties in the wording of
the Audit Report.
Although Disclaimer may not entirely eliminate the Liability to the 3rd
party but they do reduce the Scope for the Courts to assume the
Liability to them.

So can’t we conclude that Accountant does not owe any duty of care and therefore will not be liable for any loss suffered by Charles.?

Thankyou in Advance