Advocates' immunity as described in D'Orta-Ekenaike extends to claims for damages (including legal fees, unfavourable costs orders, and loss of opportunity) that are dependent upon the outcome of earlier proceedings, as such claims seek to re-litigate the earlier determination. 'Loss of Happiness in Life' and 'Public Humiliation' are not recognised heads of damage, though damages for distress, inconvenience or loss of reputation may be available if properly pleaded in connection with an appropriate cause of action. The question whether advocates' immunity applies where no earlier judgment is called into question remains not free from doubt.
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