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Since the House of Lords in Hedley Byrne & Co Ltd. v Heller and Partners Ltd [1] enunciated the possibility of professional persons owing a duty of care to third parties for the consequences of negligent mis-statements, accountants have been concerned with the extent of this duty and their potential liability. Accountants normally owe a duty of care to their client as a term of the contract of engagement and the extent of this duty has become clear from a range of cases concerning the law of contract [2]. But the duty of care owed under a contract may be different in kind to that owed to a third party under the law of tort.