The Judicial Registrar upheld the Chief Commissioner's public interest immunity claims across five categories (safety of persons, community sources, police methodology, ongoing investigations, and third party agencies) over approximately redacted pages of disclosure material, while rejecting the sole remaining claim of legal professional privilege over a Victoria Police 'Issue Cover Sheet' on the grounds that Victoria Police failed to establish an evidentiary basis for the claim and that sharing of Witness O's legal advice with Victoria Police appeared to constitute waiver. The Court confirmed that the common law, rather than the Evidence Act 2008, governed both the PII and LPP claims because the Chief Commissioner's disclosure obligation did not arise from a curial 'disclosure requirement' within s 131A, but expressly left open whether the statutory codification of disclosure duties in ss 415A and 416A of the Criminal Procedure Act 2009 might alter that analysis. The ruling reaffirmed that mere relevance of withheld material is insufficient to overcome PII; the material must be shown to be of substantial assistance to the defence in the balancing exercise.
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