Langan & Langan 2013 FCCA 258

A father obtained a subpoena to obtain documents from the mother’s workplace, and the mother objected to the range of documents sought and the extensive time span covered.

The judge ruled that a subpoena cannot be used to trawl through material in the hope of generating lines of enquiry that otherwise are not available, and that specific reasons must be given for a subpoena (fishing expedition).