A restraint of trade clause in a professional services employment contract that prohibits an employee from providing services to former clients is not limited to qualified professionals; it extends to any employee who provided recurring services of a kind that established a client-accountant relationship and created professional goodwill. A three-year restraint limited to clients personally serviced by the employee is reasonable where the employee's knowledge of client affairs creates an enduring attachment. Liquidated damages of 75% of client fees are a genuine pre-estimate of the loss of goodwill in an accounting practice and are not a penalty.
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