The power to compel production of documents under s 35 of the ICAC Act is limited to the purposes of an investigation but should not be narrowly confined; the breadth of a summons alone does not establish that it was issued for an improper purpose or unreasonably. Persons summoned to produce documents have an implied right to object on grounds of irrelevance to the investigation once informed of the nature of the complaint under s 30(3), but any ruling by the Commissioner on such an objection may only be challenged on judicial review grounds. The s 111(3) secrecy protection extends to internally created ICAC documents and prevents compulsory production of ICAC documents in court proceedings, but does not impermissibly curtail the Supreme Court's supervisory jurisdiction over ICAC.
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