Ansbacher Cayman Ltd objects to the Revenue Commissioners' attempt to "rummage at large through the leftovers" of the court-appointed inspectors' investigation into the bank's affairs, the High Court was told yesterday.

The bank claimed the Revenue is engaged in "a fishing expedition". Mr John Gordon SC, for Ansbacher, argued it would be an intolerable situation, not just for the inspectors who produced the report on his clients but also for those conducting tribunals generally, if the Revenue Commissioners were held to be correct and given the information they sought.

The Revenue has applied to the President of the High Court, Mr Justice Finnegan, for an order granting it access to material gathered by the inspectors but not included in their report. The documents involved have been lodged in court pending the outcome of the application. The Attorney General is supporting the Commissioners' application while the inspectors and the Ansbacher bank are opposing the application.

Yesterday, Mr Gordon said the legislation setting up the inquiry into his clients - Part Two of the 1990 Companies Act - provided machinery for the regulation and policing of companies. The Oireacthas had not provided legislation for anything like the application now being made by the Revenue. There was demonstrably no jurisdiction under the 1990 Act to accede to the Revenue's request.

The Revenue had been given extensive powers by the Oireacthas to enable them get information, not only from taxpayers, but from others and those powers had been increased in successive Financial Acts, Mr Gordon said. It was not for the court to see a lacuna in the Revenue's powers. Rather, it was for the Oireacthas to act should the Revenue require additional powers.

The hearing continues today.