Choksi v Government of India & Ors [2026] EWHC 217 (KB) (06 February 2026)

Choksi v Government of India & Ors [2026] EWHC 217 (KB) (06 February 2026)

Security for costs is ordered because the claimant is resident abroad, there is a real risk of non-enforcement of a costs order, the merits do not reach the threshold of a high probability of success to displace security, and there is insufficient evidence that an order would stifle the claim.

Citation
[2026] EWHC 217 (KB)
Parties
Claimant: Mehul Choksi; First Defendant: The Government of India; Second Defendant: Gurdip Bath; Third Defendant: Barbara Jarabik; Fourth Defendant: Leslie Farrow-Guy; Fifth Defendant: Gurmit Singh; Sixth Defendant: Gurjit Singh Bhandal
Jurisdiction
England and Wales
Judgment Date
06 February 2026
Procedural Posture
Civil Claim for Damages for Personal Injury (false Imprisonment, Unlawful Detention, Assault and Battery, Conspiracy) / Interlocutory Application for Security for Costs Prior to Jurisdiction and Immunity Hearing
Outcome
Applications for security for costs granted in part
Legal Topics
Security for Costs, State Immunity, Jurisdiction, Forum Non Conveniens, Personal Injury, Conspiracy, False Imprisonment, Assault and Battery
Civil Procedure Tort Law International Law Security for Costs State Immunity Jurisdiction Forum Non Conveniens Personal Injury +3 more

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Parties

Mehul Choksi

Claimant

The Government of India

First Defendant

Gurdip Bath

Second Defendant

Barbara Jarabik

Third Defendant

Leslie Farrow-Guy

Fourth Defendant

Gurmit Singh

Fifth Defendant

Gurjit Singh Bhandal

Sixth Defendant

Procedural Posture

Civil Claim for Damages for Personal Injury (false Imprisonment, Unlawful Detention, Assault and Battery, Conspiracy) / Interlocutory Application for Security for Costs Prior to Jurisdiction and Immunity Hearing

Legal Issues

  1. 1 Whether security for costs should be ordered against a claimant resident abroad under CPR 25.27
  2. 2 Whether the merits of the claim or jurisdictional challenges justify refusing security
  3. 3 Whether there is a real risk of non-enforcement of a costs order against the claimant

Ratio Decidendi

Security for costs is ordered because the claimant is resident abroad, there is a real risk of non-enforcement of a costs order, the merits do not reach the threshold of a high probability of success to displace security, and there is insufficient evidence that an order would stifle the claim.

Court Disposition

Applications for security for costs granted in part

Orders

  • Claimant to provide security for costs of £425,000 in respect of the Second and Fourth Defendants
  • Claimant to provide security for costs of £252,000 in respect of the Fifth and Sixth Defendants