Public interest immunity does not extend to patient medical records held by public hospitals, even where there are strong confidentiality concerns, because such records are not governmental in character. The protection of medical confidentiality is a matter for Parliament through legislation (such as the Health Records Act 2001 (Vic) and Health Privacy Principles), not for judicial extension of public interest immunity. Professional disciplinary bodies performing statutory regulatory functions may themselves have a claim to public interest immunity over documents obtained in investigations, analogous to the police informer immunity, though this question was not decided.
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