Outside of NDAs and other confidentiality contracts, are there any circumstances where it would be a tort for a reporter to reveal information that was shared under an "off the record" condition?
In journalism there is no legal binding solely to the phrase "off the record". This is more about journalistic moral integrity than it is about legal binding.
Can this open the reporter up to a tort case? Sure, but it would be a difficult case to win, especially if the original person were quoted.