22 Apr 2026
HKSAR v. SADLER SIMON PETER AND OTHERS
- Citation
- [2026] HKDC 720
- Court
- District Court
- Case number
- DCCC731/2024
The court held that under Hong Kong law the prosecution's disclosure duty is limited to materials in its possession or control (extendable to other public bodies where appropriate), and that on the objective dominant purpose analysis the Freshfields Report, associated interview notes and related communications were not created for the dominant purpose of obtaining legal advice or litigation advice but were part of a self-report/compliance process under Code 12.5; accordingly MLFE's claim of legal professional privilege and its collateral waiver argument failed and all contested materials in C…