The 'chilling effect' argument for maintaining public interest immunity over informer identity is significantly weakened where the informer was a lawyer who informed against their own clients, as such conduct is not the type the law is concerned to encourage and protect. The 'on the cards' test for legitimate forensic purpose means 'reasonable possibility' and is to be applied flexibly and with common sense. Where a party consents to production orders, a subsequent objection based on lack of legitimate forensic purpose is misconceived.
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