Australia: Victoria Court of Appeal reasserts that fiduciary duties may survive end of the relationship that gave rise to them

The Victoria Court of Appeal gave judgment several days ago in Schmidt v AHRKalimpa Pty Ltd [2020] VSCA 193. The decision is of note because of the discussion it contains concerning whether, and in what circumstances, fiduciary duties may survive the end of the relationship that gave rise to them. The court stated (at para. [142]): 

We acknowledge that there is authority in jurisdictions outside Victoria to the effect that a fiduciary duty does not survive the termination of the relationship that gave rise to it. However, in our view, in the absence of a contrary decision by the High Court, the law in Victoria is as stated by this Court in Edmonds [[2005] VSCA 27]. That is, depending on the circumstances of a particular case, fiduciary duties may survive the termination of the relationship that first called those duties into being".