Banque Keyser Ullman S.A. & Ors. v. Skandia U.K. Insurance Co. Ltd. & Ors. - (Court of Appeal) - 27 January 1986

The Court of Appeal declined to extend the principle that legal professional privilege is not to be accorded in respect of communications which are made for the purpose of fraud or crime, to embrace also communications between the innocent assignee or victim of a fraudsman and his own solicitor. To have done so would have involved the consequence that once there was a fraud, the party who was complaining could obtain discovery of documents otherwise covered by legal professional privilege not only against the fraud himself but against anybody else who might be in a position to give evidence.