Computer is a document

The claimant dealt in excise goods. In February 2009 several HMRC officers entered the claimant's business premises unannounced and without a warrant.

Their intention was to conduct interviews and to inspect business records including computers. The officers removed a computer server and 19 computers returning them during the following two days.

The taxpayer subsequently applied for judicial review challenging the legality of the removal of the computers on the ground that Customs and Excise Management Act 1979 s 118B did not permit their removal because they were not documents within the meaning of s 118B(1) despite the extending effect of FA 2008 s 114.

In the High Court Mr Justice Lloyd Jones said the words in FA...