Titanium Capital Investments Ltd & Anor v Jonathan Hughes & Ors [2025] EWHC 3511 (Ch) (09 December 2025)

Titanium Capital Investments Ltd & Anor v Jonathan Hughes & Ors [2025] EWHC 3511 (Ch) (09 December 2025)

The application for disclosure fails because the applicants have not shown credible evidence on which an application for a freezing injunction could be made; the evidence of dissipation is insufficient, and the revised draft order is not precluded by the stay but fails on the merits and discretion.

Citation
[2025] EWHC 3511 (Ch)
Parties
Claimant/applicant: Titanium Capital Investments Limited; Claimant/applicant: Philip Falzon Sant Manduca; Defendant/respondent: Jonathan Hughes; Defendant/respondent: Hughes Group Limited; Defendant/respondent: Medical Supplies Direct Limited; Defendant/respondent: Lyn Hughes (nee Blyth); Defendant/respondent: Berkeley Health Limited
Jurisdiction
England and Wales
Judgment Date
09 December 2025
Procedural Posture
Application Under CPR 25.1(1)(g) for Disclosure of Assets / Post Judgment, Pending Appeal, Interim Application
Outcome
Application refused
Legal Topics
Disclosure of Assets, Freezing Injunctions, Case Management, Jurisdiction Under CPR 25.1(1)(g)
Civil Procedure Commercial Law Disclosure of Assets Freezing Injunctions Case Management Jurisdiction Under CPR 25.1(1)(g)

Case Brief

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Parties

Titanium Capital Investments Limited

Claimant/applicant

Philip Falzon Sant Manduca

Claimant/applicant

Jonathan Hughes

Defendant/respondent

Hughes Group Limited

Defendant/respondent

Medical Supplies Direct Limited

Defendant/respondent

Lyn Hughes (nee Blyth)

Defendant/respondent

Berkeley Health Limited

Defendant/respondent

Procedural Posture

Application Under CPR 25.1(1)(g) for Disclosure of Assets / Post Judgment, Pending Appeal, Interim Application

Legal Issues

  1. 1 Whether the court has jurisdiction to hear an amended application for disclosure under CPR 25.1(1)(g) during a stay pending appeal
  2. 2 Whether the evidence supports a reasonable possibility of an application for a freezing injunction
  3. 3 Whether the court should exercise its discretion to order disclosure of assets in the terms sought

Ratio Decidendi

The application for disclosure fails because the applicants have not shown credible evidence on which an application for a freezing injunction could be made; the evidence of dissipation is insufficient, and the revised draft order is not precluded by the stay but fails on the merits and discretion.

Court Disposition

Application refused