Advocate's immunity applies to the substance of the conduct complained of regardless of whether the claim is framed as negligence, breach of contract, or breach of fiduciary duty. A solicitor's failure to keep clients informed about the progress and risks of litigation, particularly where the retainer extends beyond the court proceedings and the information is relevant to non-litigious alternatives, may not be sufficiently connected with the conduct of the case in court to attract the immunity. It is not a necessary precondition to the operation of the immunity that the claim would involve re-litigation of issues or a challenge to finality.
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