The lawfulness of intrusive covert surveillance under the Regulation of Investigatory Powers Act 2000 Part II would normally be sufficiently demonstrated by the production by the prosecution of the surveillance commissioner's signed approval forms or by the chief officer who had authorised and obtained approval of the surveillance giving evidence to that effect and, except in an exceptional case, the defence was not entitled to see the authorisations or any of the other underlying material placed before the surveillance commissioners for the purpose of obtaining their approvals.

[2005] EWCA Crim 887

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