—discovery rule applicable in negligent installation of an underground conduit causing flooding of plaintiff's property

Increasing acceptance of the principle of the discovery rule has extended the doctrine to contexts unrelated to medical malpractice.

—"... a plaintiff's cause of action accrues for limitation purposes when he suffers actual consequential damage or loss from the defendant's negligence."

Under that doctrine, a cause of action accrues only when the plaintiff knows or should reasonably know of his injury

Although the New Jersey court initially limited the application of the rule to medical malpractice cases, it has since been applied to a number of other contexts in which the plaintiff does not know about the cause of action.

The rule is generally established that mere ignorance of the existence of a cause of action or of the facts which constitute a cause of action will not prevent the running of the statute of limitations or postpone the commencement of the period of limitation.

The court concluded the Diamond opinion with the prophetic observation that "many of the same considerations discussed above will undoubtedly recur in situations not yet addressed by this Court. We prefer to postpone discussion of the ultimate bounds of the discovery rule until appropriate cases arise."

Telephone Co., 5 2 for example, the plaintiff instituted suit against the telephone company for its negligent installation of an underground conduit.

—plaintiffs did not discover that defendant's installation of a conduit had apparently damaged their sewer line until nine years after the event.

—or where the facts of which plaintiff is ignorant could not have been discovered by reasonable inquiry ordiligence.