The EU Court of Justice holds that communications between lawyers and their clients should be protected at the Community level as long as they were related to the client’s rights of defence and independent lawyers (AM&S)

JUDGMENT OE THE COURT 18 MAY 1982 [1] AM & S Europe Limited v Commission of the European Communities Case 155/79* 1. Article 14 (1) of Regulation No 17 empowers the Commission when investigating an undertaking to require production of "business records", that is to say, documents concerning the market activities of the undertaking, in particular as regards compliance with those rules. Written communications between lawyer and client fall, in so far as they have a bearing on such activities, within that category of documents. 2. Since by virtue of Article 14 (1) of Regulation No 17 the Commission may demand production of the documents whose disclosure it considers "necessary" in order that it may bring to light an infringement of