Where a solicitor's negligence results in property remaining encumbered by an easement that should have been removed, actual damage accrues at the time of the encumbrance, even where the client has a good equitable claim to have the easement removed. The availability of equitable remedies does not render the loss illusory or negligible. However, where the solicitor subsequently gives negligent advice that no error was made, a separate cause of action based on that advice does not accrue until the opportunity to obtain the equitable remedy is lost. The distinction between 'loss of a chance' (actual damage) and 'chance of a loss' (contingent damage) is critical to determining when the limitation period begins to run.
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