Lakhany v Hasan [2025] EWHC 3369 (KB) (22 December 2025)

Lakhany v Hasan [2025] EWHC 3369 (KB) (22 December 2025)

The injunction was discharged because the claimant failed to comply with the duty of full and frank disclosure, misrepresented key facts regarding the defendant's control over assets and his move abroad, and did not provide solid evidence of a real risk of dissipation. The procedural requirements for notice and disclosure were not met, and the order granted was wider than justified by the evidence or the judge's intention.

Citation
[2025] EWHC 3369 (KB)
Parties
Claimant: Hamza Lakhany; Defendant: Danyaal Hasan
Jurisdiction
England and Wales
Judgment Date
22 December 2025
Procedural Posture
Interlocutory Application (freezing Injunction) Within Civil Proceedings / Application to Discharge World Wide Freezing Injunction
Outcome
World-wide freezing injunction discharged
Legal Topics
Freezing Injunctions, Full and Frank Disclosure, Notice Requirements, Asset Dissipation, Costs
Civil Procedure Injunctions Freezing Injunctions Full and Frank Disclosure Notice Requirements Asset Dissipation Costs

Case Brief

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Parties

Hamza Lakhany

Claimant

Danyaal Hasan

Defendant

Procedural Posture

Interlocutory Application (freezing Injunction) Within Civil Proceedings / Application to Discharge World Wide Freezing Injunction

Legal Issues

  1. 1 Whether the world-wide freezing injunction should be discharged for lack of full and frank disclosure
  2. 2 Whether the claimant complied with procedural requirements for notice and disclosure
  3. 3 Whether there was a real risk of dissipation justifying the injunction

Ratio Decidendi

The injunction was discharged because the claimant failed to comply with the duty of full and frank disclosure, misrepresented key facts regarding the defendant's control over assets and his move abroad, and did not provide solid evidence of a real risk of dissipation. The procedural requirements for notice and disclosure were not met, and the order granted was wider than justified by the evidence or the judge's intention.

Court Disposition

World-wide freezing injunction discharged

Orders

  • The world-wide freezing injunction granted on 2 July 2025 is discharged.
  • Claimant to respond to defendant's application for indemnity costs by 12 January 2026; defendant to reply by 19 January 2026; costs order to be made thereafter.