Hassankhel v Limton [2026] EWHC 714 (KB) (20 February 2026)

Hassankhel v Limton [2026] EWHC 714 (KB) (20 February 2026)

The Claimant failed to establish any material or deliberate breach of the duty of full and frank disclosure by the Defendant, his solicitors, or counsel. Any omissions or inaccuracies were minor, inadvertent, or immaterial to the grant of the freezing injunction. The Defendant had a good arguable case for setting aside the settlement for fraud, and the interests of justice required the injunction to remain in place.

Citation
[2026] EWHC 714 (KB)
Parties
Claimant: Bahader Ghulam Hassankhel; Defendant: Cordell Javan Limton
Jurisdiction
England and Wales
Judgment Date
20 February 2026
Procedural Posture
Civil Personal Injury/fraud / Interlocutory Application to Discharge/continue Freezing Injunction
Outcome
Application to discharge the freezing order dismissed.
Legal Topics
Freezing Injunctions, Full and Frank Disclosure, Setting Aside Settlement for Fraud, Abuse of Process, Capacity to Litigate
Civil Procedure Personal Injury Fraud Freezing Injunctions Full and Frank Disclosure Setting Aside Settlement for Fraud Abuse of Process Capacity to Litigate

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Parties

Bahader Ghulam Hassankhel

Claimant

Cordell Javan Limton

Defendant

Procedural Posture

Civil Personal Injury/fraud / Interlocutory Application to Discharge/continue Freezing Injunction

Legal Issues

  1. 1 Whether the Defendant breached the duty of full and frank disclosure in obtaining the freezing injunction
  2. 2 Whether the freezing injunction should be discharged for alleged breaches
  3. 3 Whether the Defendant established a good arguable case for setting aside the settlement for fraud

Ratio Decidendi

The Claimant failed to establish any material or deliberate breach of the duty of full and frank disclosure by the Defendant, his solicitors, or counsel. Any omissions or inaccuracies were minor, inadvertent, or immaterial to the grant of the freezing injunction. The Defendant had a good arguable case for setting aside the settlement for fraud, and the interests of justice required the injunction to remain in place.

Court Disposition

Application to discharge the freezing order dismissed.

Orders

  • The freezing injunction remains in force.
  • Claimant's application to discharge the freezing order is dismissed.