When Mr Lehrmann faced criminal trial for sexual assault in the ACT Supreme Court in 2022, he was provided with material that both parties could have used to mount their arguments.

This material was not meant to be made public, because it was never used in open court. This is known as the Hearne v Street obligation.

However, it aired on the Seven Network's exclusive Spotlight interview with Mr Lehrmann.

Mr Lehrmann repeatedly gave evidence in his defamation case, on at least four occasions, that he did not provide Seven with anything more than an interview.

Justice Lee said he was "satisfied" Mr Lehrmann made false representations to the court about at least part of this material.

"In the absence of any other explanation, the inescapable conclusion is that Mr Lehrmann provided access to Mr Llewellyn to the relevant photographs," he said.

While conceding he was "not some sort of roving law enforcement official", Justice Lee left the door open for another court to pursue the alleged breach of the Hearne v Street obligation.

There seems to be a potential new path of legal inquiry here aside from any potential new case by the ACT. Punishments aren’t severe, but he could basically be found in contempt of court and fined or (unlikely) imprisoned.

https://www.abc.net.au/news/2024-04-15/act-bruce-lehrmann-defamation-trial-judgment-five-key-takeaways/103706716