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Wong v The Commissioner of Police & Anor, (1) the High Court released a party from an implied undertaking not to use documents for a collateral purpose. In this case, the documents in question had been provided by the second respondent (the respondent) to the police in support of its criminal complaint against the applicant. Copies of the documents were passed by the police to the applicant during their investigation. While the implied undertaking generally arises in the context of documents that a party is compelled to disclose to another as a result of discovery in a civil action, it can ha...

Re Chinacast Education Corp, (1) the High Court allowed a defendant's application for the release to him of a sum of money paid into court by the plaintiffs in order to fortify an asset freezing injunction that the plaintiffs had obtained against (among others) the defendant. The plaintiffs' claims ultimately failed and the injunction was discharged. The defendant, in turn, obtained a monetary judgment against the plaintiffs. In allowing the defendant's application, the High Court had to decide whether the money paid into court had been advanced to the first plaintiff by the plaintiffs' funde...