Mayo Associates v Anagram [1998] JLR 410 (08 December 1998)
Where criminal and civil proceedings arise from the same facts, confidentiality has already been breached by the criminal investigation, and the material has already been seen by the parties, the court may release a party from the implied undertaking restricting use of documents to the purpose for which they were disclosed.
- Citation
- [1998] JLR 410
- Parties
- Applicant: Mayo Associates; Respondent: Anagram
- Jurisdiction
- Jersey
- Judgment Date
- 08 December 1998
- Procedural Posture
- Civil / Interlocutory
- Outcome
- application granted
- Legal Topics
- Production of Documents, Use of Documents Obtained in Criminal Proceedings, Implied Undertaking, Confidentiality
Case Brief
Summary, issues, holding and outcome
More case intelligence is available
Unlock the full research layer for this judgment.
Parties
Mayo Associates
Applicant
Anagram
Respondent
Procedural Posture
Civil / Interlocutory
Legal Issues
- 1 Whether documents obtained in parallel criminal proceedings can be used in civil proceedings
- 2 Whether the implied undertaking restricting use of such documents can be released
Ratio Decidendi
Where criminal and civil proceedings arise from the same facts, confidentiality has already been breached by the criminal investigation, and the material has already been seen by the parties, the court may release a party from the implied undertaking restricting use of documents to the purpose for which they were disclosed.
Court Disposition
application granted
Orders
- Party released from implied undertaking to use documents only for the purpose stated in criminal proceedings
- Documents may be used in civil proceedings
Full Case Text
Judgment text and source record
Sign in to read
Sign in to read the full judgment text
Sign in to read the full judgment text. Downloads and additional research tools may depend on your plan.
Sign in to read the full judgment