California, United States of America
The following excerpt is from Priestly v. Superior Court in and for City and County of San Francisco, 319 P.2d 796 (Cal. App. 1957):
Apparently the majority has adopted the reasoning in Roviaro v. United States, 353 U.S. 53, 77 S.Ct. 623, 1 L.Ed. 639, which dealt with the necessity of disclosing the name of the informer-participant (a much stronger situation requiring disclosure than in the case of a mere informer) where the court said: 'A further limitation on the applicability of the privilege [not to disclose] arises from the fundamental requirements of fairness.' 353 U.S. at page 60, 77 S.Ct. at page 628. But apparently the following from the same case was overlooked:
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