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64 Nos. 77-1698, 77-1210 & 77-1370 The Roviaro test has been applied in the context of civil litigation in a variety of cases, see eg., Socialist Workers Party v. Attorney General, 565 F.2d 19 (2d Cir. 1977) cert. denied, 46 U.S.L.W. 3766 (June 18, 1978); Westinghouse Elec. Corp. v, City of Burlington, 351 F.2d 762 (D.C. Cir. 1965), and we see no reason to depart from this well-established rule. The language employed by the Court in Roviaro encompasses civil litigation as well as criminal litigation, and the competing interests underlying the privilege and its exceptions are essen- tially the same. in both- contexts.40 See Westinghouse, supra, 351 F.2d at 769. As the Westinghouse court concluded, “The Roviaro balance should be struck in each case, civil and criminal, in deciding whether disclosure ‘is essential to a fair determination of a cause.’ 353 USS. at 61.” Id. And in striking this balance, the court should examine the “relevance” of the informer’s information to “possible 39 continued or not should be based on a balancing test, And the two fac- tors which the McClelland court said would justify disclosure, when translated for application in the civil context, are pres- ent in the instant case: The informant may have been a witness, if not a participant, to the conspiracy which con- stitutes the basis of the action, and the reasonableness of the law enforcement. officers’ conduct is dependent upon the reliability of the informant. See id. at 485. Thus, even under McClelland, disclosure would have been appropriate. “ the determination of the guilt or innocence of a criminal defendant has been characterized as qualitatively more Significant than civil litigation, thus justifying a higher threshold of justification for exceptions to the privi ge in civil cases. However, the difference in “significance” of criminal and civil cases simply should be considered another factor in the Roviaro balancing test. Further, the proposition that all Civil cases are less significant—and therefore rea i level of justification for the disclosure of the i entity of the informer—than all criminal cases is a dubious one. It seem impossible to conclude absolutely that every criminal misdemeanor case is “more Significant” than civil] actions to redress, for example, egregious violations of an individual’s rights.