A medical centre operator that acquires practice management goodwill has a sufficient protectable interest to support post-term restrictive covenants on doctors, even though the operator and doctors are in different 'industries'. The word 'proprietary' in this context includes legitimate commercial interests. However, a plaintiff claiming damages for breach of a restrictive covenant must prove a causal connection between the breach and the loss, and evidence of general recruitment difficulty is insufficient. On tortious interference with contract, the Australian test (unlike the English position in OBG v Allan) requires that where the defendant claims the contract was terminated, the belief must be reasonably held.
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