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Ruddy v Mercury Personal Communications Ltd
Facts
The Claimant brought libel proceedings on a letter which had been disclosed in earlier civil proceedings in the County Court. Those earlier proceedings had reached trial, at which the letter complained of was read out. The implied undertaking on use of disclosed documents was therefore released - CCR Order 14 rule 8A. The Defendant in the libel proceedings nevertheless contended that it was an abuse of process for the Claimant to sue on the disclosed letter.