Bolkiah v KPMG [1998] UKHL 52; [1999] 2 WLR 215 at 225 (emphasis added). In Bolkiah v KPMG, (High Court), note 5 supra at 7, an extract from a letter that KPMG sent to Price Jefri's solicitors is included. It states in part: "The duty of confidentiality owed to clients makes it inappropriate for this firm to give you or anybody else acting for.. That was established by the House of Lords in Prince Jefri Bolkiah v KPMG [1999] 2 AC 222. As the present decision shows, however, the Bolkiah approach is limited to the former client situation. It does not apply where the solicitor received the relevant information as a result of acting for an opponent in previous litigation.

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Bolkiah v. KPMG (1998), 234 N.R. 180 (HL) MLB headnote and full text. Prince Jefri Bolkiah (appellant) v. K.P.M.G. (A Firm) (respondents) Indexed As: Bolkiah v. KPMG.. Prince Jefri had recently been removed as chairman of BIA and the assignment (Project Gemma) was at least in part adverse to Prince Jefri's interests. Pumfrey, J., granted.. Abstract. Bolkiah represents the latest decision on the increasingly litigated issue of subsequent adverse representation. While the decision is clear and rejects a number of problematic presumptions and duties imposed in other cases, its test is too stringent and unduly interferes with the client's right to choose his or her firm of lawyer.