How have the courts interpreted materiality in a complaint of non-disclosure?

In the United States of America v. Friedland, Sharpe J. recited authority for the proposition that it is no answer to a complaint of non-disclosure that if the relevant matters had been placed before the court, the decision would have been the same. He stated: 36 It is also clear from the authorities that the test of materiality is an objective one. Again to quote the Gee text at page 98: ... The duty extends to placing before the court all matters which are relevant to the court's assessment of the application, and it is no answer to a complaint of non-disclosure that if the relevant matters had been placed before the court, the decision would have been the same. The test as to materiality is an objective one, and it is not for the applicant or his advisers to decide the question; hence it is no excuse for the applicant subsequently to say that he was genuinely unaware, or did not believe, that the facts were relevant or important. All matters which are relevant to the 'weighing operation' that the court has to make in deciding whether or not to grant the order must be disclosed.