Cameron McKenzie This matter showed four issues.

Firstly the misconduct of a party (Failure of full and frank financial disclosure)

Secondly that the issue was in contention, connected to proceedings and required illumination.

Thirdly the scope and nature of the information sought was not so broad to be considered fishing.
(Thus the requirement to be careful as to the exact material being sought and upon what grounds)

Fourthly that if the material protected by privilege or confidentiality that the interests of justice will prevail over such privacy.

It must also be mentioned that confidential material such as medical records can be subpoenaed and held in the registry as confidential and only available under certain circumstances.