Conflict of laws

Eronat v Tabbah [2002] EWCA CIF 950, Court of Appeal, Lord Justice Aldous, Lord Justice Mance and Sir Christopher Slade, 10 July 2002

Conflict of laws – Dispute between partners in a business enterprise – Claimant commenced proceedings in England for unpaid commission – Defendant in possession of confidential documents belonging to claimant which could not have been obtained lawfully – Claimant seeking order against defendant preventing defendant disclosing documents to third parties – Commission claim dismissed, but defendant giving court undertakings not to disclose documents – Defendant requested by US Grand Jury to disclose documents in his possession – Whether English undertakings should be varied – Criminal Justice (International Cooperation) Act 1990, s4