I think the crux of this matter is how the car has been driven beforehand, which none of us will truest know. Let's face it, is the buyer going to say "yeah mate I cane it everywhere I go" I doubt it. I think the condition / SH is more of an indication of how the car has been driven. Mine was a car that was used as a mode of transport to get from A to B and serviced on time regardless of the cost.
My car has 100k and the previous owner owned the car from 12k. He serviced it on time, insp 2 at 52k and insp 1 at 81k. O rang the Indy who serviced it at 90k and asked about the oil - boom 10w60 before I'd finished my sentence. I asked about valve clearances, he said he'd never done a set as they don't need it. I've heard this from several indy's and from several sources on the flip side I've heard the exact opposite from other indy's. My local Indy has suggested race shells, they race M3 so you'd think they should know? I agree with Tom in that OEM shells should suffice, especially as my car is a toy and will rarely go above 6k rpm - it will on the odd occasion of course.