Practitioners seeking to use documents from earlier proceedings in subsequent estoppel or abuse of process defences may find support in the Court's obiter observations that the Harman undertaking may not apply where the connection between the proceedings is sufficiently direct, though the point was not decided.
The full text is available to signed-in members, including the 13 later cases that cite this judgment.
1 of the 13 citing cases carry a classified treatment. How each court treated it is available to signed-in members.