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Flood v Times Newspapers Ltd (Third Party Disclosure)
Facts
The Claimant brought a libel action over an article in The Times. The Defendant sought to defend the article on the basis of (a) justification of a Chase Level 3 meaning; and (b) Reynolds qualified privilege. An Amended Defence had been served making changes to both defences, but no Amended Reply had been served. The Defendant issued applications for third party disclosure against the Independent Police Complaints Commission (IPCC) and the Metropolitan Police (Met). The IPCC consented to an order for third party disclosure in September 2008. Included within the documents were documents which contained confidential and sensitive information about Boris Berezovsky. Mr Berezovsky had not been given notice of the Application against the IPCC. He opposed the making of the order against the Met on the grounds that the requirements of CPR 31.17 had not been met.