Documents relating to an application by the Director of Corporate Enforcement to have inspectors appointed to Independent News and Media may be relevant to the defence in separate legal proceedings being taken by Denis O'Brien, the High Court has been told.

Mr O'Brien has taken an action against PR firm Red Flag Consulting for alleged conspiracy and defamation.

Last month he was successful in his application to have businessman Declan Ganley joined to the action.

Mr Ganley denies he was the client for whom an allegedly defamatory dossier on Mr O'Brien was prepared.

Lawyers for Red Flag told the High Court today that its lawyers had sought access to the court documents in the ODCE case when the matter was before the High Court President yesterday.

Mr Justice Peter Kelly adjourned his decision on granting access to other parties until next week, to allow issues about possibly privileged documents to be resolved.

Barrister William Abrahamson told the court that personal data relating to some of the Red Flag personnel appeared to have been compromised and Red Flag considered it a significant possibility that matters disclosed in the court documents, if they are granted access to them, may be relevant to the company's defence in this action.

Ms Justice Miriam O'Regan made directions about the progress of the case but gave all parties liberty to make further applications if necessary.