Various Claimants v News Group Newspapers Ltd and others [2013] EWHC 2119 (Ch); [2013] WLR (D) 314
“The well established requirement for disclosure under Norwich Pharmacal principles for a party from whom disclosure was sought to be “involved” in or to have “facilitated” wrongdoing was too narrow and the court should ask itself whether the party was a mere witness or whether its engagement with the wrongdoing was sufficient to make it more than a mere witness and susceptible to the court’s jurisdiction to order disclosure.”
WLR Daily, 12th July 2013
Source: www.iclr.co.uk
