Editor’s note: This article provides general information about an NSW court decision and WHS governance. It is not legal advice. The legal question Can the sole director of a company prevent the production of corporate safety records by arguing that locating or producing them might incriminate the director personally? The NSW District Court considered that question in SafeWork NSW v Paul Whitmarsh (No. 2) [2025] NSWDC 86. The answer was no, at least where the subpoena is dire