“Plain and Obvious” Test Applies in Applications for Production of Requested Documents Under Rules of Court 2021 01 Apr 2024 In Lutfi Salim bin Talib and another v British and Malayan Trustees Ltd [2024] SGHC 85, the High Court held that the court should not go behind filed affidavits for the purposes of deciding an application under O 11 r 3(1) of the Rules of Court 2021 unless it is plain and obvious from objective evidence before court that the requested documents exist or existed, must be or have been in the respondent’s possession or control, or are not protected from production. Director Lin Shumin, who acted for the Claimants, discusses this decision. Read more here.