For limitation purposes in professional negligence claims involving pure economic loss, the cause of action accrues when actual measurable damage is first suffered, not when the damage is discovered. Where the loss is an entitlement to a stream of income, damage is suffered when the entitlement is lost (here, on judicial appointment). Where the loss is failure to obtain a tax reduction through superannuation contributions, damage is suffered at the end of the financial year when the opportunity to make contributions is irretrievably lost. Where the loss is the cost of rectifying disordered records, damage is suffered when the records reach a state requiring independent review, not when the review invoice is received.
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