In a corporatised medical practice, booking sheets belong to the proprietor, pathology reports belong to the patient (with the proprietor having superior possessory rights as bailee), and a doctor working in the practice owes an implied obligation of confidentiality concerning patient contact details. The benefit of that obligation is assignable to a purchaser of the practice, but the assignee can recover only such damages as the assignor could have recovered. A Court of Appeal decision affirmed by the High Court on different grounds is not binding on first instance judges, though it remains persuasive.
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