The disclosure to the defence of surveillance authorisations obtained pursuant to the Regulation of Investigatory Powers Act 2000 s.26 and s.32 in a redacted form was in accordance with the statutory procedure set out in the 2000 Act. Mere eavesdropping of a conversation between one person at one end of a mobile telephone or two people face-to-face was not communication in the course of transmission for the purposes of s.1 of the 2000 Act.

[2005] EWCA Crim 703