Section 84(2) of the Victims Support and Rehabilitation Act 1996 prohibits production of documents falling within s 84(1)(a)-(c) categories even where the subpoena is issued by the accused for forensic purposes, but does not extend to documents held by the Tribunal that fall outside those categories. There is no inconsistency between s 84(2) and s 150 of the Criminal Procedure Act 1986, and no implied repeal by the Crimes Legislation Amendment (Sentencing) Act 1999. The dissent (Dowd J) would have held that s 84(2) does not prevent an accused from requiring production of documents for the accused's own forensic purposes, as the prohibition only applies to documents sought to be admitted 'against' a person.
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