The second leading English case in this matter is Home Office v. Harman, supra. The issue in that case was [p. 536]: … whether it is the duty of the solicitor of one party to civil litigation, who in the course of discovery in that litigation has obtained possession of copies of documents belonging to the other party of the litigation, to refrain from using the advantage enjoyed by virtue of such possession for some collateral or ulterior purpose of his own not reasonably necessary for the proper conduct of the action on his client's behalf; and if so, whether a breach of that duty constitutes contempt of court?
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