The two-stage test for production of documents in criminal proceedings requires identification of a legitimate forensic purpose and satisfaction of the 'on the cards' test that documents will materially assist the applicant's case. The Ridgeway public policy exclusion principles may potentially extend to cases where police deliberately instigate an offence through a third party, but this was not decided. The 'on the cards' test requires more than speculation; material placed before the court must have some direct or indirect connection to the matters sought to be established.
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