CaseOutcomes
Engineering and construction · United Kingdom

KBR v Serious Fraud Office

Limits on compelling overseas documents

Appeal allowed

Outcome at a glance

KBR won its challenge to the asserted overseas reach of the SFO’s document-production power. The Supreme Court unanimously allowed its appeal.

Allegations & issues

KBR challenged a section 2(3) notice demanding documents held abroad, arguing that the SFO lacked the statutory power to compel this US company.

Key rulings & findings

Section 2(3) of the Criminal Justice Act 1987 did not permit compulsion of overseas documents from KBR, which had no UK business presence. The Court rejected the proposed sufficient-connection test.

Admissions

The appeal outcome contains no admission of wrongdoing by KBR.

Disposition

Appeal unanimously allowed on 5 February 2021.

Penalties, damages & redress

This judicial review appeal imposed no misconduct penalty.

Restrictions & obligations

The ruling limited the document power considered; it did not abolish international evidence-gathering mechanisms.

THE UNDERLYING RECORD

Primary sources

Read the full documents for their precise wording and context. Regulator summaries are identified separately from court records.

Court record · supremecourt.uk01 · Supreme Court · Case record and judgmentCourt record · supremecourt.uk02 · Supreme Court · Press summary, 5 February 2021