Rennie Produce – Full Federal Court of Australia finds that third-party documents obtained in commercial judicial proceedings were producible under a requirement issued by the tax authority
The obligation in Harman v Secretary of State for Home Department  1 AC 280 has been described as follows:
Where one party to litigation is compelled, either by reason of a rule of court, or by reason of a specific order of the court, or otherwise, to disclose documents or information, the party obtaining the disclosure cannot, without the leave of the court, use it for any purpose other than that for which it was given unless it is received into evidence.
The Court held that the Harman obligation did not impede a taxpayer, who had documents in its possession which it had obtained from a third party pursuant to a summons, from providing those documents pursuant to a requirement for information issued to it by the Commissioner of Taxation. The same conclusion respecting the primacy of the Canadian requirement provision (s. 231.2) might obtain in Canada.
Neal Armstrong. Summary of Deputy Commissioner of Taxation v Rennie Produce (Aust) Pty Ltd (in liq)  FCAFC 38 under s. 231.2(1).