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Wakefield v Channel Four Television & Others (No.3)
Comment
The Court readily accepted the GMC's proposition that documents it obtained for the purposes of its inquiry could be used by the GMC only for those purposes. The interesting question, identified by the Court, was whether that restriction was imposed on any doctor to whom the GMC then disclosed those documents in the course of its procedures. The GMC's rules did not impose any such restriction, albeit that the GMC argued that such a restriction on collateral use was imposed by analogy with Taylor v SFO [1999] 2 AC 177. The Court did not need to resolve this issue given its finding that the interests of justice required that the Defendants should be allowed to inspect the documents in the libel proceedings.