A person without a proprietorial interest in documents held by the police could not challenge the police for exceeding their powers by an application to strike out an action as an abuse of process, or by injunction. Therefore, the only remedy was by way of judicial review. However, where the police had information that tended to indicate a prima facie case of corruption against a council, the interests of justice pointed in favour of the police being entitled to reveal that information to the council.

CA (Civ Div) (Morritt LJ, Waller LJ, Tuckey LJ)


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