[1] In 1995 the NSW Legislative Council passed a resolution that there be tabled in the house, documents relating to various activities of the Government.

In 1996 a further resolution was passed stating that it would be a sufficient compliance 'for the Minister to table the documents required by delivering them to the Clerk of the House'.

[2] Michael Egan, a Member of the Legislative Council, had in his possession at least four documents capable of falling within the 1996 resolution.

'[5] The case is notable for having established that the powers and proceedings of Australia's legislative chambers are justiciable issues for the courts.

Law professor Gerard Carney described the 'constitutional significance' of the case as 'profound', as it serves to 'judicially confirm the fundamental role of each House of Parliament to scrutinize the activities of the Executive Branch'.