An accountant or auditor who negligently prepares financial statements or audit certificates relied upon by a statutory compensation fund owes a duty of care to that fund and may be liable for losses flowing from the fund's reliance on those documents. However, the chain of causation is severed where the licensed person voluntarily terminates their licence and continues to operate illegally — such conduct is not a normal occurrence in the ordinary course of things and constitutes a novus actus interveniens. Liability is therefore limited to losses arising before the voluntary illegal conduct commenced.
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