It was then followed in the case of Watson v M’Ewan  AC 480 in which the court has followed the basic principle in the Cutler case and stated that a doctor (expert witness) could not be sued for breach of a duty of confidence owed to his patient where the alleged breach occurred in the course of providing evidence for proceedings.
This concept also applies though involving elements of :
(a) false and malicious evidence as decided in the case of Roy v Prior  2 All ER 729
(b) covered conspiracy (Marrinan v Vibart  1 QB 528])
This shall be consider unfair for an attainment of justice, as the immunity awarded gives freedom to expert witnesses in manipulating their position as experts to give false evidence in court. The interested parties in the proceeding may have conspired with the experts to tamper the evidence or give contradicting statements which may put the opponents in a griever situation.