I now provide an answer to the central research question, which is as follows:

As I noted in the introduction, the central research question can be answered based on the findings that I have made in relation to the different sub-questions.

Considering the first sub-question, I assessed in Chapter 2 to what extent the courts of the examined states may – from the point of view of international legal instruments – order a party to disclose information that falls under a foreign state’s rule on legal privilege. Based on this examination, I concluded that the Hague Evidence Convention and the EU Evidence Regulation would appear only to relate to the situation in which evidence must be taken abroad from a third party, or from a location that is not accessible to the public. Accordingly, in my opinion it cannot be argued that these instruments prohibit a court of a Contracting/Member State from ordering a foreign litigant to disclose information based on an injunction. In my view, this also holds when such information falls under a foreign state’s rule on legal privilege. As a result, I conclude that courts may grant such orders based on international instruments.

This provides the first element for answering the first part of the central research question, as to whether courts may order the disclosure of such information. The second element that is required follows from the examined states’ domestic laws. Based on the study that I conducted in Chapter 3, I concluded that the courts of the examined states – except the German courts and, to a lesser extent, the French courts – may order a litigant to disclose a document in violation of a foreign state’s rules on legal privilege. Furthermore, I observed that most of the examined states’ courts seem to apply the forum state’s rules on legal privilege in relation to communications that have been shared with a foreign lawyer.