Mitchell v News Group Newspapers Ltd

Disclosure and inspection of documents – Disclosure. In the context of libel proceedings, the applicants sought third party disclosure. One third party objected. The Queen's Bench Division held that the statements made by the objecting third party were unlikely to support or adversely affect the case and disclosure was unnecessary to fairly dispose of the claim or to save costs. In relation to the other third parties, the criteria set out in CPR 31.17(3)(a) and (b) were satisfied and orders for disclosure would be made in the exercise of discretion. In the particular circumstances of the case, the public interest in disclosure clearly outweighed the interests of the individual third parties.

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