In the absence of direct assistance from sales of other grazing properties in the difficult and crucial task of examining and testing the valuation figures of the two experts, the natural step is to turn to carrying capacity and the support, if any, which the competing valuations derive from that source. There is judicial authority of long standing that the value of grazing properties can best be determined on a carrying capacity basis: Fisher v Comm Land Tax (1914) 20 CLR 242, 252-253; Kiddle v Comm Land Tax (1920) 27 CLR 316, 319-320. -Hardie J in Lodge v WC&IC (1967) 14 LGRA 88, 92

The manner of use of the sheep area basis of valuation ie the value of the area that will carry a sheep by Mr T was also the subject of criticism by the appellant on the ground that the nett returns of the respective properties were not known and that such knowledge was essential to the use of such a basis of valuation. In my view this is not an essential element of this method of valuation. It is also my view that particularly in cases where the carrying capacities of the properties are not the same, the sheep area basis gives a more accurate basis of comparison of values - Mansfield CJ, Union Trustee v Comm of Tax, The Valuer, July, 1962, p202 at p207

A purchaser of the subject property at the relevant date would, in my view, have made extensive inquiries from the plaintiff and from all other sources, particularly the Pastures Protection returns, as to what the property had carried in the past; in other words, the sort of inquiry and investigation made by Mr McN. I am of the opinion that a purchaser would have paid much more regard to what the property had carried in the past than the view of experts a to what it was capable of carrying - Hardie J in Lodge v WC&IC (1967) 14 LGRA 88, 93

In the Board's view, a proper standard of valuation requires as a starting point, a detailed knowledge of the land and improvements not only with respect to the property to be valued as at the date of valuation, but also with respect to the basic sale properties as at the date of sale. In this regard, hearsay knowledge and fragmentary inspections when driving along roads or when engaged on other business matters are quite
inadequate. Furthermore, comparable sale prices must be analysed in such a way as to deduce units of value capable of application to a valuation of the property or properties to be valued. Usually the unit value deduced from a sale must be further adjusted to bring some or all of its components to some basic standard (eg average district standard). The amount of the deduced unit value, as adjusted, can then be compared with
the amounts of similar-type unit values deduced from other sales. Before applying such a unit in a valuation, corresponding adjustments must be made with respect to its components to allow for differences between the property to be valued and the basic standard." Case ED 1/262, The Valuer, April, 1972, p119 at p121.

Objection was raised to the use of sheep area values in this way, but I think that they may be open to smaller margins of error than acreage values for it is obvious that there must be a broad correspondence between sheep area values for lands in the same general locality and having similar uses and potentialities" Else-Mitchell J in Watkin v VG, The Valuer, October, 1974 p305 at p 307

The Board considers that "flock sheep" is a better standard for carrying capacity than "breeding ewes" for the type of properties concerned, because it is in accord with actual stocking. As a result, it reduces to a minimum the need for conversion from one type of stock to another when calculating carrying capacity from the records of stock actually carried.
The Board also agrees with the method of expressing the carrying capacity in terms of sheep only with the understanding that some cattle are also carried" " - Case ED 1/262, The Valuer, April, 1972, p119 at p129.