Where a solicitor's negligence in conveyancing results in a client acquiring property without development consent that was readily discoverable through ordinary conveyancing procedures, actual loss is suffered at the date of exchange of contracts — not when the regulatory authority discovers the defect. The absence of development consent is not a latent defect or contingent loss; the use is already prohibited, and the property is immediately worth less. The possibility of subsequently applying for development consent goes to mitigation, not to whether loss has accrued for limitation purposes.
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