In Western Australia, a party masking portions of a discovered document on grounds of irrelevance bears the onus of satisfying the court that masking is appropriate. A solicitor's affidavit asserting irrelevance is not conclusive. The court may inspect the unmasked document and will be guided by broader case management objectives under O 1 rr 4A and 4B, not confined to relevance alone. The English approach in GE Capital v Bankers Trust, previously followed in WA, is no longer to be applied.
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