When can a lawyer obtain an investigation report from the accident investigator?

In conclusion, I make reference to the judgment of Craig J. (as he then was) in Bowers v. White (1977), 1977 CanLII 327 (BC SC), 2 B.C.L.R. 355 at 357-58 (S.C.), as follows: The principal argument of the appellant with respect to the investigation report is that (1) the case was a "simple" intersection collision, (2) the defendant White was clearly at fault because he attempted to make a left-hand turn when he should not have attempted to do so, and (3) a law student could have obtained the same information, and material in the report, e.g., photographs, was unnecessary because of the obvious liability of the defendant. The appellant submits, therefore, that the report was unnecessary. The report contains five type-written pages of information, a scale diagram of the intersection with a plastic overlay showing the position of the vehicles, traffic lights and five 7" x 4 1/2" photographs of the intersection. There is some information in the report which a lawyer would normally have to obtain but much of the information could have been obtained by a lawyer or a law student. On the other hand, the report is well-prepared and shows a comprehensive investigation. I am inclined to doubt most lawyers would have gone to the extent to which the investigator did in this case. Of course, if a lawyer acting for the plaintiff had obtained this information through his own efforts or the efforts of his staff, he could not have charged for this in preparing his party and party costs, except to the extent that he expended moneys in the course of his investigation. On the other hand, I think that the report would have been of great assistance and, obviously, would be helpful to the plaintiff's lawyer. In my opinion, it was "proper" for counsel for the plaintiff to obtain this report, even though he could have obtained much of the information by his own efforts or by the efforts of his employees.