Revenue and Customs Commissioners v Charman and another [2012] EWHC 1448 (Fam), [2012] All ER (D) 256 (May)
As a general rule, documents and other evidence produced in ancillary relief proceedings (now financial remedy proceedings) were not disclosable to third parties outside the proceedings, save that exceptionally and rarely and for very good reason they could be disclosed with the leave of the court. The fact that evidence might be relevant or useful was not by itself a good enough reason to undermine that rule.
