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Woodward v Santander UK Plc [2010] EAT

The main exception to the rule that "without prejudice" communications are not admissible in evidence is where "the exclusion of what was communicated in without prejudice negotiations would act as a cloak for perjury, blackmail or other "unambiguous impropriety". The impropriety must be unambiguous - there is no authority for an easing of that requirement where the impropriety is alleged to be discrimination. 

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