Ang v Reliantco Investments Ltd & Anor [2020] EWHC 2529 (Comm) (24 September 2020)

Ang v Reliantco Investments Ltd & Anor [2020] EWHC 2529 (Comm) (24 September 2020)

The application for third party disclosure was dismissed except as to BT invoices for leased IP addresses, because the requests for documents relating to DeMorgan Ltd, the Wright Family Trust, and VPN configuration were too broad, insufficiently specific, not shown to be relevant or necessary, or the documents did not exist or were not in Dr Wright's control. Only the BT invoices were sufficiently identified, potentially relevant, and likely to exist.

Citation
[2020] EWHC 2529 (Comm)
Parties
Claimant: Mrs Ramona Ang; Defendant/applicant: Reliantco Investments Limited; Respondent: Dr Craig Wright
Jurisdiction
England and Wales
Judgment Date
24 September 2020
Procedural Posture
Commercial Court Application for Third Party Disclosure / Interlocutory Application Prior to Trial
Outcome
Application dismissed in part; granted only as to disclosure of BT invoices for leased IP addresses.
Legal Topics
Third Party Disclosure, Breach of Contract, Disclosure of Documents, Relevance and Necessity of Evidence
Civil Procedure Commercial Law Third Party Disclosure Breach of Contract Disclosure of Documents Relevance and Necessity of Evidence

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Parties

Mrs Ramona Ang

Claimant

Reliantco Investments Limited

Defendant/applicant

Dr Craig Wright

Respondent

Procedural Posture

Commercial Court Application for Third Party Disclosure / Interlocutory Application Prior to Trial

Legal Issues

  1. 1 Whether the jurisdictional requirements for third party disclosure under CPR 31.17 are satisfied
  2. 2 Whether the court should exercise its discretion to order third party disclosure against Dr Craig Wright
  3. 3 Relevance and necessity of documents relating to DeMorgan Ltd, Wright Family Trust, and VPN configuration/IP addresses

Ratio Decidendi

The application for third party disclosure was dismissed except as to BT invoices for leased IP addresses, because the requests for documents relating to DeMorgan Ltd, the Wright Family Trust, and VPN configuration were too broad, insufficiently specific, not shown to be relevant or necessary, or the documents did not exist or were not in Dr Wright's control. Only the BT invoices were sufficiently identified, potentially relevant, and likely to exist.

Court Disposition

Application dismissed in part; granted only as to disclosure of BT invoices for leased IP addresses.

Orders

  • Dr Craig Wright to disclose BT Openworld invoices for the lease of relevant IP addresses, subject to further submissions on the scope of the order.
  • Costs order in favour of Dr Wright for the dismissed application and for compliance with the BT invoices disclosure order.