A subpoena seeking production of documents already obtained under a statutory notice is not an abuse of process where the subpoena issuer's knowledge of the documents came from independent sources and there is a bona fide reason for seeking production under the subpoena, such as doubt about the validity of the statutory notice. Documents relating to a broader period than the specific days charged are not outside the legitimate scope of a subpoena where they are arguably relevant as tendency or coincidence evidence, to negative a defence, or to sentencing.
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