“…h criminal offences will be investigated and how that investigation will be conducted. See, for examples, R (Bermingham) v Director of the Serious Fraud Office [2006] EWHC 200 (Admin) and R (Soma Oil and Gas Limited) v Director of the Serious Fraud Office [2016] EWHC 2471 (Admin).…”
“…e cases relied on by HMRC and referred to by the judge (R v Panel on Takeovers and Mergers, ex parte Fayed [1992] BCC 524; R (Bermingham) v Director of the SFO [2006] EWHC 200 (Admin), [2007] QB 727; Sharma v Browne Antoine [2007] 1 WLR 780 (PC)). He submits that the criminal context in those cases was different; here we are concerned with a…”