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Tufano v Vincenti
Held
(1) It was unnecessary for the hearing to take place in private but an order would be made under CPR 31.22 to restrict the use of D's report about C. (2) The report was published on an occasion of absolute privilege and/or D was immune from suit. (3) There was no evidence of wider publication. (4) Having held as the Court did in (2) above it was not necessary for the Court to determine whether the claim was an abuse of process nor could it come to a definitive conclusion on the evidence.