“Where documents had been placed before a judge and referred to in the course of court proceedings, access should generally be permitted on the open justice principle. Where access was sought for a proper journalistic principle the case for allowing it would be particularly strong. The court would undertake a fact-specific proportionality exercise where there were grounds of opposition to the application for disclosure.”
WLR Daily, 3rd April 2012
Source: www.iclr.co.uk