29 Jun 2015
CITIC PACIFIC LTD v. SECRETARY FOR JUSTICE AND ANOTHER
- Citation
- CITIC PACIFIC LTD v. SECRETARY FOR JUSTICE AND ANOTHER
- Court
- Court of Appeal
- Case number
- CACV7/2012
The Court rejected the narrow client definition in Three Rivers (No 5) for Hong Kong and held that legal advice privilege should be governed by the dominant purpose test: documents and communications prepared or brought into existence with the dominant purpose of obtaining legal advice are protected even if generated by employees outside a formal legal department, subject to established limits (raw materials exception, multiple purposes assessment); accordingly the Judge erred in denying privilege on the basis that only the Group Legal Department constituted the client.