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Lloyd's Maritime and Commercial Law Quarterly

DISGORGEMENT FOR BREACH OF CONTRACT AND FOR A CRIMINAL OFFENCE

Attorney-General v. Blake
In Attorney-General v. Blake 1 the Attorney-General sought to ensure that Blake, a convicted spy who escaped from prison and fled to Moscow, did not profit from the publication of his autobiography, which contained an account of his activities as a member of the secret services. The practical effect intended by the Attorney-General was to prevent Blake’s publisher, Jonathan Cape, from paying over any further royalties to him. The information disclosed in the book was no longer confidential, and no claim based on breach of confidence was in issue. However, publication nevertheless came, the Court of

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