ABSTRACT
Disclosure is the procedure whereby one party to an action must disclose to the other party, by means of a list, the existence of all documents which are or have been in his control and which are directly relevant to the issues in the action.1 Disclosure procedure refers to the disclosure and inspection of documents, as opposed to facts. ‘Documents’ include not only originals and photocopies of printed papers but also photographs, plans, tape recordings (including audio, video and video surveillance tapes) and computer programs. In short, ‘documents’ refers to any recorded information.2
