Is there any case law where disclosure of settlement documents is privileged?

The defendants acknowledge that the documentation they seek is protected by settlement privilege. However, they submit that this privilege is not absolute and is subject to exceptions, one of which is where disclosure of the settlement documentation would prevent double recovery: Pete v. Lanouette, 2002 BCSC 75.

The defendants submit that based on the plaintiff’s evidence at discovery and the medical evidence, the injuries suffered by the plaintiff in the three accidents are indivisible. They rely on Ashcroft v. Dhaliwal, 2008 BCCA 352 for the principle that where multiple independent torts lead to indivisible injuries, the tort-feasors are jointly and severally liable to the plaintiff, and that, in such cases, damages are assessed globally, and the proceeds of settlement of any of the individual torts are deducted from the final award at trial.