It may be that the reasons of the chambers judge do not quite state the Martin v. MacDonald tests accurately in two or so places, as the appellant’s counsel alleges. In particular, he says that the reasons suggest that (a) the relationship between the past and the present retainers must be incontrovertible, and (b) the person complaining must show that information was got in the first retainer which is truly harmful to the first client in the second retainer.
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