Webster v HMRC [2023] EWHC 2697 (KB) (16 October 2023)

Webster v HMRC [2023] EWHC 2697 (KB) (16 October 2023)

The Claimant was not entitled to redact the identity of the third party funder from disclosed documents, as the court had already determined the relevance of such documents and there was no legal basis for redaction absent privilege.

Citation
[2023] EWHC 2697 (KB)
Parties
Claimant/respondent: Jennifer Marie Bridgett Webster; Defendant/applicant: His Majesty's Revenue and Customs
Jurisdiction
England and Wales
Judgment Date
16 October 2023
Procedural Posture
Disclosure Application in Civil Proceedings / Pre Trial Review; Application for Inspection of Documents
Outcome
Application granted
Legal Topics
Disclosure of Documents, Abuse of Process, Third Party Funding, Redaction of Documents
Civil Procedure Media Law Disclosure of Documents Abuse of Process Third Party Funding Redaction of Documents

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Parties

Jennifer Marie Bridgett Webster

Claimant/respondent

His Majesty's Revenue and Customs

Defendant/applicant

Procedural Posture

Disclosure Application in Civil Proceedings / Pre Trial Review; Application for Inspection of Documents

Legal Issues

  1. 1 Whether the Claimant is entitled to redact the identity of a 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 disclosed documents, as the court had already determined the relevance of such documents and there was no legal basis for redaction absent privilege.

Court Disposition

Application granted

Orders

  • Claimant must disclose the identity of the third party funder by de-redacting the relevant documents.