ABSTRACT
Sir Eric Sachs: As was pointed out in Tufton v Sperni [1952] 2 TLR 516, the relationships which result in such a duty must not be circumscribed by reference to defined limits; it is necessary to ‘refute the suggestion that, to create the relationship of confidence, the person owing the duty must be found clothed in the recognisable garb of a guardian, trustee, solicitor, priest, doctor, manager, or the like’ (Sir Raymond Evershed MR).
