The applicability of the Human Rights Act to private citizens.
The courts have a duty to develop the common law in line with Convention rights.
The court argued that it could protect confidential information in exceptional cases where it was strictly necessary. It would appear that the court will utilise the HRA in disputes between private parties only in exceptional circumstances, and where there are significant human rights issues at stake. This probably means that the courts will refrain from employing the HRA in all but the most extreme cases.
The court wants to protect the privacy of celebrities against journalists using particularly intrusive methods of photography. The court felt that it was necessary to develop a positive institutional obligation to respect privacy.
It's possible that Douglas v Hello [2001] will lead to the development of a new tort of invasion of privacy.