A solicitor's negligent advice that a client has no prospects of success in a primary claim does not postpone the accrual of the client's cause of action against the solicitor for that negligent advice. The Hawkins v Clayton principle (that a limitation period does not run while the wrongful act precludes bringing proceedings) requires a coincidence between the negligent conduct and the concealment of the cause of action — it does not apply where the negligent advice about one claim does not prevent the client from discovering a separate right to sue the solicitor. Limitation defences may be determined on summary judgment where the postponement principle relied upon is inapplicable as a matter of law to the pleaded facts.
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