Jennifer Marie Bridgett Webster v HMRC

Jennifer Marie Bridgett Webster v HMRC

The Claimant was not entitled to redact the identity of the third party funder from the disclosed documents because the court’s previous order required disclosure of documents relating to third party funding, and there was no legal basis for redaction such as privilege. The issue of relevance had already been decided against the Claimant, and the Claimant did not appeal or seek variation of the order.

Parties
Claimant/respondent: Jennifer Marie Bridgett Webster; Defendant/applicant: His Majesty’s Revenue and Customs
Jurisdiction
England and Wales
Judgment Date
03 July 2024
Procedural Posture
Civil / Interlocutory Application for Inspection of Documents (disclosure Dispute)
Outcome
Application granted
Legal Topics
Disclosure, Abuse of Process, Third Party Funding, Redaction, Public Interest
Civil Procedure Disclosure Abuse of Process Third Party Funding Redaction Public Interest

Case Brief

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Parties

Jennifer Marie Bridgett Webster

Claimant/respondent

His Majesty’s Revenue and Customs

Defendant/applicant

Procedural Posture

Civil / Interlocutory Application for Inspection of Documents (disclosure Dispute)

Legal Issues

  1. 1 Whether the Claimant is entitled to redact the identity of the third party funder from disclosed documents
  2. 2 Whether Deputy Master Fine’s Order required disclosure of the funder’s identity
  3. 3 Whether there is any legal basis for redaction absent privilege

Ratio Decidendi

The Claimant was not entitled to redact the identity of the third party funder from the disclosed documents because the court’s previous order required disclosure of documents relating to third party funding, and there was no legal basis for redaction such as privilege. The issue of relevance had already been decided against the Claimant, and the Claimant did not appeal or seek variation of the order.

Court Disposition

Application granted

Orders

  • Claimant to allow inspection of documents with the identity of the third party funder unredacted (de-redaction ordered)