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[1999] VSC 96
Supreme Court of Victoria
1999-03-31
Gillard J
Original judgment source is linked above.
Evidence - Legal professional privilege - Copy of privileged documents handed by
client to another - Whether copy protected - Whether privilege waived - Copy still protected - No waiver
"Every person in the Kingdom, except the Sovereign, may be called upon and is bound to give evidence, to the best of his knowledge, upon any question of fact material and relevant to an issue tried in any of the Queen's Courts, unless he can show some exception in his favour, such, for instance, as that suggested to exist in this case, namely that to answer might put him in peril of criminal proceedings."
"The object and meaning of the rule is this: that as, by reason of the complexity and difficulty of our law, litigation can only be properly conducted by professional men, it is absolutely necessary that a man, in order to prosecute his rights or defend himself from an improper claim, should have recourse to the assistance of professional lawyers, and it being so absolutely necessary, it is equally necessary to use a vulgar phrase, that he should be able to make a clean breast of it to the gentleman whom he consults with a view to the prosecution of his claim, or the substantiating his defence against the claim of others; that he should be able to place unrestricted and unbounded confidence in the professional agent, and that the communications he so makes to him should be kept secret, unless with his consent (for it is his privilege, and not the privilege of the confidential agent) that he should be enabled properly to conduct his litigation. That is the meaning of the rule."
"The rationale of this head of privilege, according to traditional doctrine, is that it promotes the public interest because it assists and enhances the administration of justice by facilitating the representation of clients by legal advisers, the law being a complex and complicated discipline. This it does by keeping secret their communications, thereby inducing the client to retain the solicitor and seek his advice, and encouraging the client to make a full and frank disclosure of the relevant circumstances to the solicitor. The evidence of the privilege reflects, to the extent to which it is accorded, the paramountcy of this public interest over a more general public interest, that which requires that in the interest of a fair trial litigation should be conducted on the footing that all relevant documentary evidence is available. As a head of privilege legal professional privilege is so firmly entrenched in the law that it is not to be exorcised by judicial decision. Nonetheless there are powerful considerations which suggest that the privilege should be confined within strict limits."
"The privilege which attaches by the invariable practice of our courts to communications between solicitor and client ought to be carefully preserved. In my opinion the rule is, once privileged, always privileged."
(Emphasis added)
"There is, however, an abundance of authority in support of the proposition that once legal professional privilege attaches to the document ... that privilege attaches for all time and in all circumstances."
See Giannarelli v. Wraith (No. 2) [1991] HCA 2; (1991) 171 CLR 592 at 601.
"Legal professional privilege is concerned with communications, either oral, written or recorded and not with documents per se."
"The test is anchored to the purpose for which the document was brought into existence; the use to which a document is put after it is brought into existence is immaterial."
"In applying this principle, a word is necessary about copies. If the original document is privileged (as having come originally into existence with the dominant purpose aforesaid), so also is any copy made by the solicitor."
"Unless the document was brought into existence for the purpose of putting it before the legal adviser legal professional privilege does not attach to it. Whilst neither of the cases I have mentioned deal specifically with the question of copies I am satisfied that legal professional privilege attaches to a draft or copies of a document which is itself entitled to that privilege, at least if the existence of a draft or copy represents a reasonably necessary stage in the preparation of the document to which the privilege attaches."
"Where a document satisfies the test for legal professional privilege at common law, any copy or copies of that document may also fall within the ambit of the protection afforded by that doctrine. Indeed it has been suggested that a copy of a privileged document which is brought into existence for non-privileged purposes is itself privileged: Brambles Holdings Ltd v. TPC (No. 3) [1981] FCA 83; (1981) 58 FLR 452 at 458 per Franki, J; Cross on Evidence, 5th Aust. edn (1996) at 710. A copy of a document containing purely legal advice may be regarded, prima facie at least, as privileged, absent evidence to suggest the copy was brought into existence for a purpose wholly unconnected with the purpose behind the creation of the original. Indeed, it has now been determined that, at common law, legal professional privilege may attach to copies of non-privileged documents when those copies were brought into existence solely for use in obtaining legal advice, or for use in apprehended litigation: Propend (supra)."
"The circumstances in which a waiver of legal professional privilege will be imputed by operation of law cannot be precisely defined in advance. The most that can be done is to identify a number of general propositions. Necessarily, the basis of such an imputed waiver will be some act or omission of the persons entitled to the benefit of the privilege. Ordinarily, that act or omission will involve or relate to a limited actual or purported disclosure of the contents of the privileged material. When some such act or omission of the person entitled to the benefit of the privilege gives rise to a question of imputed waiver, the governing consideration is whether 'fairness requires that his privilege shall cease whether he intended that result or not.' That does not mean however that an imputed waiver must completely destroy the privilege. Like an express waiver, it can be limited so that it applies only in relation to particular persons, materials or purposes."
"The question of whether a waiver should be implied depends on whether it would be unfair or misleading to allow a party to refer to or use material and yet assert that that material, or material associated with it, is privileged from production."
Declare that the documents produced to the court by David John Beatty contained in a folder marked "privilege" are protected from disclosure by reason of the first to twenty-first defendants', right to legal professional privilege and the plaintiffs are not entitled to production or inspection of the said documents.
I certify that this and the 12 preceding pages are a true copy of the reasons for judgment of Gillard, J of the Supreme Court of Victoria delivered on 31 March 1999.
Australian Hospital Care
Duggan [1999] VSC 96
(1976) 135 CLR 674
(1997) 188 CLR 501
(1991) 171 CLR 592
(1981) 58 FLR 452
(1984) 2 NSWLR 652
(1995) 185 CLR 83
(1986) 161 CLR 475