24 May 2023
WSSA v. SYH
- Citation
- [2023] HKFC 94
- Court
- Family Court
- Case number
- FCMC4633/2020
The court refused the Rule 121 application because, on a proportionality balancing exercise, the petitioner's request to disclose a large volume of confidential matrimonial materials to assist a non‑party criminal defendant did not justify lifting the implied undertaking; the applicant failed to show necessity, bona fides and that the materials could not be appropriately handled within criminal process, and the court retained jurisdiction to hear the application despite a pending recusal.