Under the statutory scheme of s.20C Taxes Management Act 1970, the validity of a search warrant depended not upon its particularity, but only upon the matters set out in that section. Furthermore, when executing a warrant upon a solicitors' office, the Revenue was not obliged to allow for a claim to legal professional privilege which was merely potentially valid, but was entitled to arrange for the presence of counsel to determine there and then whether such a claim could be "maintained", ie not merely made, but sustained. * Leave to appeal to the House of Lords refused.

QBD (Tuckey LJ, Moses J)

05/11/1999

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