Titanium Capital Investments Limited & Anor v Jonathan Hughes & Ors

Titanium Capital Investments Limited & Anor v Jonathan Hughes & Ors

The applicant failed to provide credible evidence of asset dissipation sufficient to justify disclosure under CPR 25.1(1)(g); the evidence presented falls below the low bar required for jurisdictional and discretionary relief.

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
13 February 2026
Procedural Posture
Application / Ruling on Disclosure Application Under CPR 25.1(1)(g)
Outcome
application refused
Legal Topics
Freezing Injunctions, Asset Disclosure, Case Management Discretion
Civil Procedure Commercial Law Freezing Injunctions Asset Disclosure Case Management Discretion

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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 / Ruling on Disclosure Application Under CPR 25.1(1)(g)

Legal Issues

  1. 1 Whether the applicant is entitled to asset disclosure under CPR 25.1(1)(g)
  2. 2 Whether credible evidence exists to support a possible freezing injunction
  3. 3 Whether the application meets jurisdictional and discretionary requirements

Ratio Decidendi

The applicant failed to provide credible evidence of asset dissipation sufficient to justify disclosure under CPR 25.1(1)(g); the evidence presented falls below the low bar required for jurisdictional and discretionary relief.

Court Disposition

application refused