Wong Wai Man v Hospital Authority

Determines when time begins to run for negligence claims under the Hong Kong Limitation Ordinance (Cap 347), applying accrual principles to latent damage.

A contingent liability does not constitute actionable damage for limitation purposes until the contingency materialises, so time does not run until then.

In tort, a cause of action for latent damage accrues when physical damage occurs, not when the claimant discovers or could have discovered it.