Professional services firms often receive requests for disclosure of documents in their possession. Such requests may take many forms, including pre-action requests for disclosure, third party disclosure requests, Norwich Pharmacal (court order for disclosure of documents or information available in the UK) orders, data subject access requests and requests from regulatory bodies. 

In the recent case of Omers Administration Corporation v Tesco plc [2019] EWHC 109 (Ch) the High Court had to consider documents provided to the Serious Fraud Office (SFO) pursuant to a request under section 2 of the Criminal Justice Act 1987 (CJA 1987).