Where a solicitor's negligence creates the opportunity for a client's fraud, the client's deliberate fraud breaks the chain of causation, and the solicitor is not liable for the full loss flowing from the fraud. The solicitor's liability is limited to the loss directly attributable to the negligent advice itself (here, the difference between the purchase price and actual value). Fraud by a client is not, in the ordinary course of events, something likely to flow from a solicitor's negligent act, and a solicitor does not owe a duty to guard against the risk of fraudulent conduct by the client.
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