A master's characterisation of a privilege claim as 'litigation privilege' when 'own case privilege' was actually claimed constitutes error requiring remittal. The 'matrix of facts' relating to a party's dealings is not a proper basis for ordering production of redacted material that is irrelevant to any pleaded issue. An unresolved conflict exists in the WA General Division as to whether the redacting party or the challenging party bears the onus on redaction disputes.
The full text is available to signed-in members, including the 6 later cases that cite this judgment.