Breen V Williams Essay

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V. ROLE OF LEGISLATION
As discussed briefly in the preceding paragraphs, the role of legislation rarely plays a part within the law of fiduciaries. However, as mentioned above, this essay will argue that the Australian courts have failed to adequately adapt the principles of equity to meet the needs of modern day society in relation to fiduciary duties. The law of equity has remained ‘frozen’ and has therefore lost its fundamental and underlining principle ‘to look at reality as it finds itself now.’

In Breen v Williams the issue of whether or not there was a doctor/patient fiduciary relationship present was based on Mrs Breen’s argument that the doctor had a positive obligation to provide her with her medical records. Without this underlying argument, the issue of the fiduciary relationship would not have arisen. Therefore, it became the High Court’s initial focus to consider whether or not there was a prescriptive obligation on doctors to provide patients with their medical records. Once the answer to that question was …show more content…

Justice Gummow in Breen v Williams considered that the doctor/patient relationship might be one which constitutes a fiduciary one. However, he concluded that the patient’s claim failed on the basis that the patient had not satisfied the second step of the two-fold test for determining the existence and scope of fiduciary duty, that is, by demonstrating the extent and nature of the obligations on the doctor extended to providing the patient with her medical records. If such obligation could be demonstrated through the AMA’s guidelines (if they were in existence during the time of judgment), it could be concluded that Justice Gummow would have considered that the second step of the two-fold test had been satisfied and thus that the doctor/patient relationship was in fact a fiduciary one in

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