Although s 37 of IA 2005 provides immunity from civil claims for inquiry panel members, s 38 implicitly confirms that that immunity does not serve to
preclude judicial review claims in respect of decisions made by a member or members of the inquiry panel.
The Court found that the decision in the
Judicial Review proceedings did not determine any civil law
claim for damages and consequently the SFO was not
precluded from disputing liability for trespass.