David Cunningham King was indicted on 322 counts including fraud, tax evasion, exchange control contraventions, money‑laundering and racketeering, arising mainly from alleged schemes to externalise assets and evade tax exceeding R1 billion. During extensive pre‑trial litigation, King sought an order compelling the National Director of Public Prosecutions (NDPP) to furnish him with a ‘motivated index’ of all documents in parts B and C of the police docket (internal memoranda, investigation diaries, prosecutors’ notes and communications), including a description of each document and reasons for refusing access. The North Gauteng High Court granted this relief. The NDPP appealed, contending that while the accused is entitled to relevant, exculpatory or helpful material under the fair‑trial right as articulated in Shabalala, there is no general right to a motivated index of all privileged or irrelevant docket material.