Duty of disclosure limited to documents which are or have been in party’s controlE+W
31.8—(1) A party’s duty to disclose documents is limited to documents which are or have been in his control.
(2) For this purpose a party has or has had a document in his control if—
(a)it is or was in his physical possession;
(b)he has or has had a right to possession of it; or
(c)he has or has had a right to inspect or take copies of it.