The governing choice of law rule for legal professional privilege claims in Australia is the lex fori (Australian law), whether because no choice of law issue arises under the Potter v Minahan statutory construction principle (Jagot and Bromberg JJ) or because the connecting factors with the forum direct attention to the lex fori (Besanko J). Australian law of privilege applies to documents seized under Australian statutory powers even where the documents were created overseas by foreign lawyers under a foreign retainer.
The full text is available to signed-in members, including the 6 later cases that cite this judgment.
2 of the 6 citing cases carry a classified treatment. How each court treated it is available to signed-in members.