Gelber v Griffin: FD 22 Nov 2006

Complaint was made that a party had disclosed confidential material received through disclosure to a third party.
Held: There was an implied duty of confidence arising in the disclosure process.

Judges:

Pearl J

Citations:

[2006] EWHC 3666 (Fam)

Links:

Bailii

Jurisdiction:

England and Wales

Citing:

CitedPrudential Assurance Co Ltd v Fountain Page Ltd 1991
A party and his legal representatives receiving documents under a process of discovery is under an implied undertaking to use those documents for the purposes of those proceedings only. It is an obligation imposed by operation of law by virtue of . .
CitedAllan v Clibbery (1) CA 30-Jan-2002
Save in cases involving children and ancillary and other situations requiring it, cases in the family division were not inherently private. The appellant failed to obtain an order that details of an action under the section should not be disclosed . .

Cited by:

CitedDavies v Welch Admn 4-Nov-2010
The applicant sought the committal of the respondent for contempt. The defendant, a solicitor had acted for the claimant’s wife in ancillary relief proceedings. He complained that documents sent to her under implied undertakings of confidentiality . .
Lists of cited by and citing cases may be incomplete.

Contempt of Court

Updated: 21 July 2022; Ref: scu.279025