Ang v Reliantco Investments Ltd & Anor

Ang v Reliantco Investments Ltd & Anor

The application for third party disclosure was dismissed in respect of documents relating to DeMorgan Ltd, the Wright Family Trust, and VPN configuration because the requests were too broad, insufficiently specific, and the Defendant failed to demonstrate relevance and necessity. The court found that Dr Wright credibly stated he did not possess the requested documents. However, the application was granted in respect of BT invoices for leased IP addresses, as these may exist, are sufficiently identified, and could be relevant to the issues at trial.

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 (third Party Disclosure) / Ruling on Application for Third Party Disclosure Prior to Trial
Outcome
Application dismissed in part and granted in part
Legal Topics
Third Party Disclosure, Breach of Contract, Disclosure of Documents, Jurisdictional Requirements, Relevance of Evidence
Civil Procedure Commercial Law Third Party Disclosure Breach of Contract Disclosure of Documents Jurisdictional Requirements Relevance of Evidence

Case Brief

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Parties

Mrs Ramona Ang

Claimant

Reliantco Investments Limited

Defendant/applicant

Dr Craig Wright

Respondent

Procedural Posture

Commercial Court Application (third Party Disclosure) / Ruling on Application for Third Party Disclosure Prior to Trial

Legal Issues

  1. 1 Whether the Defendant is entitled to third party disclosure orders against Dr Wright under CPR rule 31.17
  2. 2 Whether the documents sought are relevant and necessary for the fair disposal of the claim or to save costs
  3. 3 Whether the application for disclosure is proportionate and sufficiently specific

Ratio Decidendi

The application for third party disclosure was dismissed in respect of documents relating to DeMorgan Ltd, the Wright Family Trust, and VPN configuration because the requests were too broad, insufficiently specific, and the Defendant failed to demonstrate relevance and necessity. The court found that Dr Wright credibly stated he did not possess the requested documents. However, the application was granted in respect of BT invoices for leased IP addresses, as these may exist, are sufficiently identified, and could be relevant to the issues at trial.

Court Disposition

Application dismissed in part and granted in part

Orders

  • Application for third party disclosure against Dr Wright dismissed except for BT invoices relating to leased IP addresses, which are to be disclosed if they exist and are within Dr Wright's control.
  • Dr Wright granted liberty to apply to vary the order if compliance is disproportionate, time-consuming, or delayed.