Brewer Management Corporation v Christie Manson & Woods Ltd [2026] EWHC 126 (Ch) (30 January 2026)

Brewer Management Corporation v Christie Manson & Woods Ltd [2026] EWHC 126 (Ch) (30 January 2026)

Although the gateways for security for costs were established, it was not just to order security in this case because Christie's counterclaim raised the same issues as BMC's claim, meaning the litigation would proceed regardless of the outcome of the security application. The existence of the Yukhnovich painting and the undertakings offered, while not a complete answer, were relevant discretionary factors. There was insufficient evidence that Mr Ghandehari was a 'good mark'.

Citation
[2026] EWHC 126 (Ch)
Parties
Claimant/respondent: Brewer Management Corporation; Defendant/applicant: Christie Manson & Woods Limited; Part 20 Defendant: Sasan Ghandehari
Jurisdiction
England and Wales
Judgment Date
30 January 2026
Procedural Posture
Security for Costs Application in Ongoing Commercial Litigation / Interlocutory Application Prior to Case Management Conference
Outcome
Application for security for costs dismissed
Legal Topics
Security for Costs, Jurisdiction, Company Law, Counterclaims, Enforcement of Judgments
Civil Procedure Commercial Law Security for Costs Jurisdiction Company Law Counterclaims Enforcement of Judgments

Case Brief

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Parties

Brewer Management Corporation

Claimant/respondent

Christie Manson & Woods Limited

Defendant/applicant

Sasan Ghandehari

Part 20 Defendant

Procedural Posture

Security for Costs Application in Ongoing Commercial Litigation / Interlocutory Application Prior to Case Management Conference

Legal Issues

  1. 1 Whether security for costs should be ordered against a foreign-resident claimant company
  2. 2 Whether the existence of a counterclaim raising the same issues precludes security for costs
  3. 3 Whether the claimant's disclosed asset (a painting) or undertakings are sufficient to defeat the application for security

Ratio Decidendi

Although the gateways for security for costs were established, it was not just to order security in this case because Christie's counterclaim raised the same issues as BMC's claim, meaning the litigation would proceed regardless of the outcome of the security application. The existence of the Yukhnovich painting and the undertakings offered, while not a complete answer, were relevant discretionary factors. There was insufficient evidence that Mr Ghandehari was a 'good mark'.

Court Disposition

Application for security for costs dismissed

Orders

  • Mrs Ghandehari to provide undertakings to the Court as indicated