Lim Suk Ling Priscilla and another v Amber Compounding Pharmacy Pte Ltd [2020] SGCA 76
Significance: Singapore Court of Appeal held that a multifactorial balancing exercise is to be adopted in determining whether a party ought to be released from its Riddick undertaking not to use documents ordered to be disclosed in civil proceedings for collateral purposes. The previous two-step test in Beckkett Pte Ltd v Deutsche Bank AG [2005] 3 SLR(R) 555, viz. inter alia prejudice as overriding factor, is not to be applied.
Search orders (or Anton Piller orders) should be targeted and specific in their reach; the breadth of search orders should be carefully calibrated to meet the needs of the discovering party only, and no further.