What are the damages for a solicitor who fails to disclose material facts about a secret profit on a real estate transfer?

The decision of this court in Jacks v. Davis is indistinguishable from this case on all the relevant points. The damages that should be borne by a solicitor who fails to disclose to his client material facts about the secret profit on a real estate transfer are to be computed in a similar way to damages for fraud, namely, by determining the amount of the overpayment for the land in excess of what it was worth. Additionally, where the transfer would not have occurred if the true facts had been known, the damages should also include all further consequential losses, even if those losses are not such as would reasonably have been foreseeable or as would reasonably have been in the contemplation of the parties, subject only to considerations relating to the plaintiff's own actions in mitigation, to legal remoteness determined by a common sense view of the strength of causation and not by foreseeability, and to such interrelated factors as new intervening acts.