Home Information Cases Process Development Ltd v Hogg (1995)

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Process Development Ltd v Hogg (1995)


Duty of solicitor supervising the execution of an Anton Piller order and disclosure of information concerning the order to the police.


Employee's appeal against order releasing his employer from Anton Piller confidentiality undertakings as to the employer's own documents which had been recovered from the employee under the order and permitting him to disclose the same to the police together with the supervising solicitor's report.


(1) The disclosure and handing over of documents recovered under the order to the police did not involve a breach of the rule that a person was not to be compelled on the pain of a penalty to testify against himself.(2) However the supervising solicitor was there to ensure the order was properly executed with proper regard to the defendant's interests. There was no reason why the plaintiff's solicitor should not describe the circumstances in which the documents were delivered up or the defendant's admissions, but not his report itself. Appeal dismissed but the order would be varied to exclude the supervising solicitor's report.

Court of Appeal
Sir Thomas Bingham MR, Rose LJ, Hobhouse LJ
Judgment date
24 May 1995

[1996] FSR 45 : (1996) 19(2) IPD 19012