Pledgee of shares cannot be treated as a third party when seeking documents relied on for attachment proceedings.

A pledgee of shares was held entitled to apply for copies of documents relied upon for an attachment order, and for that limited purpose it could not be treated as a third party. The statutory scheme permits disclosure subject to privacy concerns, but the request must be made in the prescribed form and with the requisite fee. The attachment order was treated as provisional and as having spent itself on the passing of the assessment order, so quashing of that order was not pursued in the writ proceeding. The respondents were directed to consider any proper application in a time-bound manner.

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Issues: Whether the petitioner, as pledgee of shares, was entitled to seek copies of documents relied upon for the attachment order and whether it could be treated as a third party for denying such information.

Analysis: The attachment order was treated as provisional and as having spent itself on the passing of the assessment order, so quashing of that order was not pursued in this writ proceeding. On the request for documents, the statutory scheme permits furnishing information subject to privacy concerns and the application must be made in the prescribed form with the requisite fee. The petitioner, being the holder of the pledge over the shares, was directed not to be treated as a third party. The respondents were required to consider any such application in a time-bound manner.

Conclusion: The petitioner succeeded only to the extent of being entitled to seek consideration of its application for documents and to be treated as not a third party for that purpose; the challenge to the attachment order was not granted.

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