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In a landmark decision, the High Court of Australia determined that a non-delegable duty of care may be breached by the intentional conduct of a delegate, overturning longstanding authority of New South Wales v Lepore (2003) 212 CLR 511, which found that a common law non-delegable duty could not arise in respect of harm caused by an intentional criminal act. The decision significantly refines the scope and operation of non-delegable duties in Australian law.