The 'on the cards' and 'could possibly throw light on' tests for legitimate forensic purpose of a subpoena require a concrete ground for belief that the documents will materially assist on an identified issue; the phrases must not be given a reach wider than intended so as to permit speculative demands. A subpoena seeking a competitor's entire trading and financial records to enable an expert to ascertain whether a causal link exists between a defendant's breach and the plaintiff's loss is properly characterised as fishing where the plaintiff has not identified a concrete basis for the expected correlation.
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