51 There are numerous reasons why Mr Stevens' time analysis is flawed. Mr Stevens assumed that each page in each document needed to be perused before a proper decision to seize could be taken. But many company registers and trust deeds were taken: once an executing officer identified such a document from a perusal of only the first page, he might well be justified in seizing the whole. I have already referred to the AFP practice of seizing an entire file where it contained a document identified as within the relevant warrant. Mr Stevens also based his analysis on the assumption that each executing officer perused a document ultimately taken only in the period between when that document was logged in the seizure record in the "time located" column and when the immediately preceding document taken by that officer was similarly logged. As might be expected, the notation in the "time located" column for a document records the time when many executing officers, after having completed their perusal of the relevant document, had determined that it should be seized. The respondents, in their submissions, point to numerous other reasons for rejecting Mr Stevens' time analysis as of any value as evidencing an undiscriminating search and seizure.
52 But notwithstanding all this, I think the applicants' attack on the execution of the warrants succeeds in part. Save only for documents that could be thought to be related in some way to the Hendon and Northbourne Trusts (and the RD Moore Family Trust), the AFP and ATO officers brought in to execute the warrants had, I think, little option but to conduct a negative search, ie, to take anything that they thought might turn out at some future stage to be of some relevance to proof of the offences referred to in very general terms in the warrants.
53 A small team under Federal Agent Perry had the carriage of the investigation within the AFP from November 1995, when the ATO called in the AFP, at least until a decision to issue the warrants in question was taken. The main focus of the investigation was on the suspected use by the applicants of a trust, the Hendon Unit Trust, as a vehicle for generating substantial fee income for the applicants by enabling a number of their clients to avoid tax in the financial years 1991 to 1995. In setting out details of the scheme involving the Hendon Unit Trust, it should be recorded that no facts have yet been found as to whether the applicants or any of their clients at whose premises the warrants were executed have been involved in any unlawful tax avoidance scheme or other unlawful activity. Details of the scheme and other activities are taken from allegations made by the respondents in the material filed in the present proceedings which are concerned solely with whether seizure of the documents was lawfully authorised by the warrants.
54 According to Federal Agent Leary, prior to executing the search warrants, the AFP had detailed information that pointed to the Hendon Unit Trust being the centre of an unlawful tax avoidance exercise orchestrated by the applicants. According to this information, the applicants arranged for each client involved to make distributions from the client's own discretionary trust to the Hendon Trust, purportedly by way of investment in the business activities of that Trust. The client would make a commitment on or prior to 30 June to invest a certain sum in the particular financial year in the Hendon Trust. Twelve percent of this investment would be paid in cash, with 10 percent going to Astion, one of the second applicants and a company controlled by Messrs Hart and Adcock, and the other 2 percent going to Tinkadale Pty Ltd ("Tinkadale"), a company controlled by Mr and Mrs Adcock and Mr Stevens. These sums were retained by Astion and Tinkadale for their own benefit as what were described as management fees. They comprised the benefit to the applicants from the scheme. The balance of 88percent of each client's investment was, so it was believed by the ATO and the AFP, never paid to Hendon but instead was evidenced only by a journal entry in the books of the client's discretionary trust for the relevant year as a distribution by that trust to Hendon in the form of a loan to that Trust payable at call. Though Hendon brought to account in its tax returns income amounts equal to 88 percent of each client's purported investment, the Hendon Trust did not have to pay any tax in any of the years of income because that Trust had large losses accumulated from previous years' trading against which it was able to write off that income. Each client's trust claimed in its relevant tax return to have distributed income in an amount equalling 100 percent of the payments made in the particular financial year to Astion, Tinkadale and Hendon. If this investment had not been made into the Hendon Unit Trust by the client trust in the particular financial year, then the client trust would have had to pay tax on undistributed income or the beneficiaries would have had to pay tax on any distributions of income.
55 What made the arrangement attractive to clients, according to the information obtained by the ATO and the AFP, was that the clients were told that the applicants, as controllers of the Hendon Trust, would never demand payment of the 88 percent of the investment purportedly made by each client trust in Hendon: these moneys were instead retained by those controlling each client trust for their own purposes.
56 In interviews conducted by AFP and ATO officers in January 1996, an unidentified client of Harts stated that the Hendon Unit Trust was set up as a means of reducing that particular client's tax. This client said he was informed by Mr Hart that, apart from the 12 percent cash payment, "they would not have to pay the balance of their investment [in the Hendon Trust] as it would never be called up". In February 1996, ATO officers obtained information from two unidentified ex-employees of Harts to the effect that each had received a memo from Mr Stevens inquiring whether the employee had any clients interested in putting money into a trust with tax advantages and that, in this context, each ex-employee sighted various documents concerning the Hendon Unit Trust. Each told the ATO officers that Mr Stevens, in response to their query, said the balance of loans or contributions shown in the books of clients who participated in these arrangements as owing to the Hendon Unit Trust would never be called up.
57 In February 1996, ATO officers also interviewed Mr James Zannes and Mr Theodore Tzannes, principals of a car dealership. They told the ATO officers that Mr Hart introduced an investment scheme involving the Hendon Unit Trust to them when he visited them at Moree prior to the end of the 1993 financial year. The 1993 financial year return for the Zannes Brothers Unit Trust showed a net profit of $232,223, of which $200,000 was invested in the Hendon Unit Trust. The Zannes told the ATO officers that, apart from $20,000 paid to Astion and $4,000 to Tinkadale, they did not, on the basis of what they were told by Mr Hart, expect to have to pay anything more of the $200,000 written up as an investment in the Hendon Unit Trust. Mr Theodore Tzannes also said they did not appreciate that "the Hendon Unit Trust was involved in the scheme, or that their trust was actually making a distribution to it" until they applied for a loan from their bank in the first half of 1994. The bank had then obtained the 1993 financial statements for the Zannes Brothers Unit Trust prepared by Harts and queried them about the $200,000 liability to the Hendon Unit Trust recorded in these statements. The Zannes called on Mr Hart to answer this query, which he did by a letter of 21 June 1994, in which he stated "Please be advised that there are no monies owing to the Hendon Unit Trust by the Zannes Brothers Unit Trust.".
58 The same unidentified client already mentioned also gave information to the effect that documents amending clients' trust deeds were sent to clients for signing approximately eighteen months after the journal entry distributions to the Hendon Unit Trust were created. This was done, so it was suspected by the AFP, to ensure that the trustees of the client trusts could show that they were authorised to invest in the Hendon Trust in financial years long past. In March 1996, ATO officers obtained information from another ex-employee of Harts to the effect that, though Messrs Adcock and Hart each signed statutory declarations in connection with the tax affairs of the relevant clients to the effect that documentation relating to clients' trust distributions to the Hendon Unit Trust had been signed prior to 30 June 1993, much of that documentation was, in fact, only executed after the end of that financial year. If true, apart from other possible criminal activities, the applicants also engaged in falsifying documents upon which the tax liabilities of the clients in question depended.
59 Prior to executing the search warrants, the AFP investigation thus had what, on its face, was cogent information that the Hendon Unit Trust was employed by the applicants as a vehicle for unlawful tax avoidance by their clients to the mutual benefit of the clients and the applicants. They also had cogent evidence to suggest that the applicants were involved in backdating or altering financial records and documents in connection with their use of the Hendon Unit Trust for this purpose. Information available to the ATO and AFP from taxation records of fifty-seven trusts that contributed to the Hendon Unit Trust indicated that "at least $13 million of otherwise taxable income has been distributed by way of journalised loans to the Hendon Unit Trust in the 1992/93, 1993/94 and 1994/95 financial years".
60 The information available to the AFP concerning the Northbourne Holdings Unit Trust suggested that the applicants used this Trust as a tax avoidance vehicle for clients in the same way as they used the Hendon Unit Trust (though the contributions made by journal entry by various of the Harts' client trusts apparently intended to go to the Northbourne Holdings Unit Trust were written up in the client taxation returns prepared by Harts as having been made to the "Northbourne Rural Property Trust"). Examination of client taxation records by the ATO suggested that approximately $2,700,000 of taxable income was distributed by client trusts to the Northbourne Trust.
61 The investigation, however, was into a range of activities by the applicants, those associated with them and various clients, that extended beyond the schemes said to be centred on the Hendon and "other similar trusts". It is apparent from Federal Agent Leary's evidence that, prior to executing the warrants, the AFP also had a range of information, some of it suggesting that various persons in the Harts organisation engaged at Mr Hart's instigation in the practice of falsifying clients' financial records on the basis of which tax returns were prepared to reduce the clients' tax liability. The AFP had information suggesting that balance day adjustment "journal entries" were made within the Harts organisation, quite separately from what was done in respect of clients involved with the Hendon and Northbourne Trusts: this had the effect of reducing clients' taxable income by overstating the business creditors of clients, by journalising under-valuations of stock on hand or not bringing all stock on hand to account at the end of the financial year. Two persons, an employee and an ex-employee of Harts, provided information to this effect to the ATO in November 1995 and March 1996. This is what was called the third of the seven lines of inquiry in aid of which the police obtained the warrants. The Hendon and Northbourne matters were the first two lines of inquiry.
62 The AFP also had information that Mr Hart, on occasion, received payment from clients for accounting services provided in the form of goods and services. The value of such goods and services was not declared by Mr Hart or his company as income, while charges to the clients which were raised in Harts' books for the accounting services were then written off as bad debts. Specific reference was made to plumbing and electrical services said to be provided to Mr Hart personally. But the AFP's information was that there were many instances in which this kind of arrangement was put in place between Mr Hart and personal clients. This was the fourth line of inquiry.
63 AFP information also suggested that a number of entities associated with the applicants had avoided tax by simply not lodging returns. Tinkadale, as trustee for the New Stewart Family Trust, had not lodged tax returns, though, for the 1992 financial year, it had receive a distribution of nearly $70,000 from the Adcock Practice Trust. The Adcock Practice Trust received over $450,000 from Astion and Tinkadale for the financial years 1993 - 1995 inclusive. Advice by Harts to the ATO in respect of Astion and Tinkadale was to the effect that all outgoings from both companies were payments made by them by way of consultant or management fees and were thus taxable in the hands of the recipient. Yet the Adcock Practice Trust had not lodged a tax return for any of the 1993 - 1995 financial years. This was the fifth line of inquiry.
64 Federal Agent Leary also deposes to suspecting a failure by entities to bring to account all income derived during a particular financial year and to overstate deductions. He refers to distributions from various family trusts associated with Mr Hart brought to account in the tax returns for the relevant year by those trusts, but not included in the income of the various recipients. This was the sixth line of inquiry.
65 Finally, the ATO received information in April 1996 to the effect that Harts Consulting Pty Ltd, a company controlled by the applicants, was involved in a scheme with forty-two clients, each of whom agreed to pay a fee of $40,000 to Harts Consulting for a business management report. Only $16,250 of this fee was in fact paid by each client. The client was to claim the full $40,000 as a deduction in the relevant year. Harts Consulting undertook not to call up the balance of the fees and declared as income only the $16,250 cash actually received. This was the seventh line of inquiry.
66 These matters, commencing with the Hendon matter, are identified as the seven lines of AFP inquiry referred to in the letter from the AGS to the applicants' solicitors of 30 July 1998. This letter was written in connection with the cataloguing exercise. The applicants say it was the first indication to them that the scope of the AFP/ATO investigation in aid of which the warrants were issued in fact extended beyond activities involving the Hendon and Northbourne Trusts.
67 The evidence before me establishes that the many AFP and ATO officers brought in to assist the small number of AFP and ATO officers already involved in the investigation to execute the warrants were briefed, not only about the suspected involvement of the applicants and various of their clients in criminal offences in connection with the Hendon and Northbourne schemes, but also about the range of other suspected offences referred to above.
68 Federal Agent Morris' briefing notes (exhibit H3) were displayed as part of his PowerPoint presentation at the briefings held on 5, 8 and 9 September 1996. It is apparent from these notes that the AFP and ATO officers there present were given a detailed description of how the Hendon Unit Trust was believed to have been used by the applicants in carrying on tax-related criminal activity. The attention of all those officers was expressly drawn to the belief of the AFP and ATO investigators that the applicants were "defrauding the Commonwealth of Taxation revenue by way of a unit trust called the HENDON Unit Trust as well as a number of other similar trusts of which the structure is set up solely for the purposes of avoiding tax". That statement is contained in p 2 of the PowerPoint presentation, which I accept was displayed at the briefings. The client table, which Federal Agent Morris displayed at his briefings, shows that those officers were also given quite detailed information about the family and business trusts of twelve of the applicants' clients who were believed to have avoided tax on very large sums purportedly invested in the Hendon and Northbourne Trusts, particularly in the financial years 1993 to 1995.
69 The Willemse Family Trust was the thirteenth client trust investor included in the table in Federal Agent Morris' PowerPoint document. Unlike the others, Federal Agent Morris' table does not show the Willemse Family Trust as having made any payments to either Hendon or Northbourne. Instead, it shows payments by the Willemse Trust to entities described as "RD Moore Family Trust", "Neutral" and "Sunpro". The RD Moore Family Trust would, in this context, very likely be understood by those briefed as another "similar trust" to Hendon. The respondents also had information suggesting that the Willemse Family Trust was connected with the Hendon Trust. Federal Agent Leary sets that out in some detail. The Hendon Unit Trust was established in March 1988, with a company called The Westside Commerce Centre Pty Ltd as trustee. Prior to its acquisition by the applicants, that company had acquired, as such trustee, a commercial property in Adelaide called "Hendon Common", with funding largely obtained from an external financier. In late 1990, this financier entered into possession of the property as mortgagee, the debt owing to it in April 1996 being $19,250,000. By this time, all units in the Hendon Trust were held by another company, RD Moore Pty Ltd, as trustee for the RD Moore Family Trust. A Mr Robert Moore was director and principal shareholder in RD Moore Pty Ltd and the owner with another of the shares in The Westside Commerce Centre Pty Ltd.
70 On 30 June 1993, Mr Moore caused RD Moore Pty Ltd as trustee of the RD Moore Family Trust to grant an option to the applicant, Astion, to buy the units in the Hendon Unit Trust, all of which it owned. Federal Agent Leary says that the AFP had information that though it was Astion which held the call option over the shares in RD Moore Pty Ltd, in August or September 1993, Mr Moore transferred the shares in RD Moore Pty Ltd and thus ownership of the units in the Hendon Trust to Queensland Mushrooms Pty Ltd ("Queensland Mushrooms"), a client of Harts. The directors and shareholders of Queensland Mushrooms, Ms Clark and Messrs J Willemse and P Willemse, are recorded in Australian Securities Commission records as directors of RD Moore Pty Ltd in the period 30 June 1993 to 7 July 1995, when RD Moore Pty Ltd was struck off the register. The respondents thus had information that, for some years from August or September 1993, the Hendon Trust, which was central to one of the tax avoidance schemes that they believed the applicants were engaged in, was owned and controlled by the same people who were the directors of Queensland Mushrooms, who were also associated with the Willemse Family Trust.
71 One of these, Ms Clark, said it was Mr Hart who suggested that the Willemses should buy RD Moore Pty Ltd. She also said, however, she was not aware that RD Moore Pty Ltd, of which she and her two brothers, Messr P and J Willemse, were directors, had any connection with the Hendon Unit Trust, though it seems that the company owned all the units in Hendon: she said she knew nothing about it. Mr P Willemse said the same. Some of Queensland Mushrooms' financial and other records that were seized contain references to both the Hendon Unit Trust and the Willemse Family Trust. But it does not matter what the true position was among the Willemses and Ms Clark. Even if it is the case that they knew nothing about the connection between their company, RD Moore Pty Ltd, and the Hendon Unit Trust, that is not relevant to the question of the lawfulness of the execution of the warrants at the premises of Queensland Mushrooms.
72 In my opinion, the information that the AFP and ATO officers who were conducting the investigation had suggesting a connection between Ms Clark and Messrs P and J Willemse, the Willemse Family Trust, Queensland Mushrooms and the Hendon Unit Trust through RD Moore Pty Ltd, was sufficient to entitle those officers to form a reasonably grounded suspicion that documents relevant to showing that connection as well as documents at the premises of Queensland Mushrooms that mentioned or related to the Hendon Unit Trust all satisfied condition 3 of the relevant warrants.
73 That these officers held such a suspicion in relation to Queensland Mushrooms and those who controlled it was, I think, conveyed to the mass of AFP and ATO officers involved in the execution of the warrants at one or other of the various briefings by the display of Federal Agent Morris' PowerPoint document. As I have pointed out, this document expressly drew the attention of those at the briefings to the belief that the applicants were using the Hendon Unit Trust, as well as a number of other similar trusts, solely for the purpose of the unlawful avoidance of tax and the client table in this document is likely to have indicated to those who viewed it that the "RD Moore Family Trust", to whom the table shows the Willemse Family Trust as having made payments in the 1993 to 1995 period, was one of those "similar trusts".
74 The document CAJ-1, "Documents Behind the Scheme", was prepared by Mr McKay of the ATO, who also participated in the execution of the warrants. There are understandable differences in the recollections of various of the officers, some no longer with either the AFP or the ATO, about the range of information they gathered at the briefings. But I accept that CAJ-1 was widely distributed at one of the briefings, probably the one attended by the ATO Officer Jeffs with other ATO and AFP officers in early September. It depicts, though not as in much detail as Federal Agent Morris' PowerPoint presentation notes, the activities involving the Hendon and Northbourne Unit Trusts. It provides those to whom it was given fairly detailed information about the involvement of Harts' client trusts in the Hendon scheme and lists seven particular categories of document to be "looked for" as documents associated with the Hendon scheme and therefore to be seized under the warrants.
75 Given the information available to the ATO and the AFP, including that to the effect that Hendon and Northbourne had large accumulated losses and would receive nothing at all from the purported investments in them by the applicants' clients, it can be inferred that the AFP and ATO officers running the investigation into the applicants' activities associated with Hendon and Northbourne were of the view that neither entity was engaged in any lawful activity, but had been used by the applicants and their clients entirely as vehicles for unlawful tax avoidance. As I have said, just that view of Hendon "as well as a number of other similar trusts", including Northbourne, was expressed by Federal Agent Morris at the briefings he gave to AFP and ATO officers involved in executing the warrants.
76 Once it is concluded that the ATO and the AFP investigators had reason to view both Hendon and Northbourne as vehicles employed by the applicants and their clients solely for unlawful tax avoidance and that the officers involved in the execution of the warrants were informed at the briefings they were given of that, I think it follows that any document discovered by any of the executing officers at any of the premises of the applicants or their clients which could be seen to relate in any way to activities involving the Hendon or Northbourne Trusts could be said to be within the relevant warrant. Once the conclusion is reached that all the ATO and AFP officers involved in execution of the warrants had grounds for thinking that both the Hendon and Northbourne Trusts (and the RD Moore Family Trust) were employed by the applicants solely as vehicles for unlawful tax avoidance, it follows, in my opinion, that, for all practical purposes, an officer who considered that a document that answered the first two conditions of the relevant warrant also mentioned or in some other way related to the activities of Hendon or Northbourne (or the RD Moore Family Trust) was entitled without further consideration to seize the document: such a document would necessarily satisfy the third condition of the relevant warrant.
77 The applicants' challenge to the seizure of any hard copy document that in any way relates to any of these three trusts must therefore fail. The systemic failure to have regard to condition 3 of each warrant now at the centre of the applicants' case, even if established, cannot invalidate the seizure of any of those documents.
78 The information available to the AFP and ATO officers running the investigation and conveyed to the executing officers at the various briefings in relation to the five lines of inquiry additional to the Hendon and Northbourne lines was, in significant respects, more general than that conveyed to the executing officers in relation to the Hendon and Northbourne lines of inquiry. In relation to these other five lines of inquiry, the executing officers were (with two qualifications) given only the broadest information as to the kind of activities that it was suspected the applicants and various clients had engaged in which might involve the commission of one or other of the offences listed in the warrants.
79 Despite its title, "Documents Behind the Scheme", CAJ-1 draws the attention of those to whom it was given to a number of areas of activity in which it was thought the applicants and others may have been involved in criminal activity additional to activities concerning the Hendon Trust. It contains more detailed information than that in Federal Agent Morris' PowerPoint notes about the third line of inquiry, under the heading "False Journal Entries" in Section 2. The briefing document, CAJ-1, thus gave a little more precise guidance to executing officers as to some of the kinds of documents they should look for in relation to this line of inquiry and it appears from Federal Agent Morris' PowerPoint presentation that those attending his briefings may also have been given some specific, but limited, information of examples of conduct engaged in by Mr Hart in relation to the fourth line of inquiry.
80 But generally, the information given to executing officers in relation to the other five lines of inquiry was so broad as, in my opinion, to make it practically impossible for officers who were not themselves closely involved in the investigation to be able to form any view in relation to a particular document that it might well be of relevance to proving one or other of the offences named in the warrant. Most of the executing officers were brought in to the matter solely for the purpose of the execution exercise, ie, they had no other involvement in the investigation. It may well be that they were in the position of being able to say no more than that the documents which they took in connection with the five lines of inquiry other than those relating to Hendon and Northbourne might possibly turn out, on further examination, to be of relevance to one or other of the offences in the warrants. It may well be that all such officers were quite unable to reach the requisite state of mind that any of the documents, each seized because they might relate to one of the other five lines of inquiry, could reasonably be suspected of affording evidence of the commission of an offence.
81 The applicants abandoned their original challenge to the seizure of the material taken that required a document by document evaluation. Instead, they sought to prove by evidence of general application to the entirety of the material taken that execution of all the warrants was flawed with the systemic failure referred to. The respondents joined issue with the applicants on this question. They were as keen to avoid litigating the validity of the seizure of each piece of material taken as the applicants ultimately became. A consequence of the way the parties have conducted the case is that the respondents have answered the applicants' allegation of a systemic failure said to taint the entire execution exercise with evidence and argument of their own that is at a relatively high level of generality. This approach creates a difficulty for evaluating the respondents' claims as to the validity of the seizure of the very large number of documents they say relate to the five lines of inquiry separate from the Hendon and Northbourne matters. The respondents have not sought to demonstrate that particular documents they have catalogued as relevant to one of the seven lines of inquiry in aid of which they used the warrants can so obviously be seen from its face to have that quality as to answer the claim of improper seizure of that document. It is possible that, despite the vague information many (but not all) the executing officers had about such lines of inquiry, there may be some documents which could on their face be seen to have been properly seized because they clearly relate to one of these five lines of inquiry. But the way the case was fought resulted in the respondents not seeking to justify the seizure of any individual documents as relevant to those inquiries. The Court is not in a position to attempt such an exercise.
82 It is this consideration, coupled with what has emerged from the cataloguing exercise, that leads me to the conclusion that the applicants' challenge, based as it is on the systemic failure referred to, is made out in relation to all the documents taken other than those which mention or which in some other way relate to the activities centred on the Hendon, Northbourne and RD Moore Trusts.
83 I consider that the outcome of the cataloguing process undertaken in this case is important, for a number of reasons.
84 I accept the applicants' submission, supported as it is by the evidence of Federal Agent Negus and other AFP witnesses as to how they went about cataloguing the documents, that the AFP was then concerned to determine whether reasonable grounds could be said to exist for the seizure of each document they catalogued. The small team of AFP officers involved in the cataloguing process relied upon their own assessment. That is, they were concerned in that process only with whether the documents they evaluated were seizable, not with whether they were validly seized. They could not reach a conclusion on the latter issue without reference to the particular officer who made the seizure of the particular document and that was not done.
85 The applicants also submit that, because they too were concerned in the cataloguing process only with determining whether documents were seizable and not with whether they were validly taken, they are entitled to the return of the small amount of documents, which they conceded were lawfully taken in the course of the cataloguing process, if they make out their case that the whole execution process was systemically flawed because those executing the warrants did not take into account condition 3 of the various warrants. Even if the applicants' case that the whole execution process was flawed and that all documents taken should be held to have been unlawfully seized were established, the fact remains, as the respondents point out, that the consent order of 7 June 1999 authorised the release to the respondents of those documents conceded by the applicants in the course of the cataloguing process as being within the warrant. The respondents have thus had unrestricted access to that class of documents ever since, with the consent of the applicants. Relief under s 16 the ADJR Act is discretionary and can be refused, in a proper case, even though the applicant succeeds in showing the decision in question is flawed with error. I would expect that all these documents relate to the Hendon and Northbourne Trusts. I have rejected the applicants' challenge to the seizure of all such documents. But, even if the applicants had succeeded in making out their case as to these documents, I would not, in view of what occurred on 7 June 1999, order the return of the documents the subject of that order.
86 That the AFP agreed, in the course of the cataloguing exercise, that the seizure of certain documents was not authorised by law does not itself show that seizure of those documents in reliance on the warrant could not be justified at the time they were taken. As I have said, the validity of the seizures cannot be governed by what happens afterwards, including what happened as by the outcome of a more leisurely evaluation of the documents than was available to the officers engaged in executing the warrants at the various premises. As Viscount Dilhorne said in Rossminster at 1,006 of an operation involving the seizure of a great many documents: