An allegation of improper purpose in obtaining a search warrant must be particularised; it is not sufficient to assert that the absence of a proper purpose leads to an inference of improper purpose where the factual basis for excluding proper purpose is not established. A Deed of Settlement compromising civil tax claims does not give rise to an inference that a criminal investigation has ended. Discovery will not be ordered in judicial review proceedings where the allegations are bare and unparticularised, even where the underlying decision was made in camera.
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