Police owe no private law duty of care to individuals in the exercise of their public duties, including in fatal shooting situations, unless there is an express or implied assumption of responsibility to the particular plaintiff. The mere fact that police are in charge of an operation does not amount to an implied assumption of responsibility. Zalewski v Turcarolo [1995] 2 VR 562 is of very limited precedent value in light of Sullivan v Moody, Tame v New South Wales, and D'Orta-Ekenaike v Victoria Legal Aid.
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