Disclosure and inspection of documents – Disclosure against persons not parties to proceedings. In the context of proceedings seeking damages from the Serious Frauds Office, the judge ordered disclosure of five reports prepared by the appellant chartered accountants and joint liquidators. They appealed on the basis that the judge had erred in finding that the reports were not protected by litigation privilege. The Court of Appeal, Civil Division, in dismissing the appeal, held that the judge had not mischaracterised the proper approach and that there was no basis on which to legitimately differ from the judge's assessment that the dominant purpose test had not been satisfied.