Lenkor Energy Trading DMCC v Irfan Iqbal Puri

Lenkor Energy Trading DMCC v Irfan Iqbal Puri

Given the entry of an English judgment, the law's policy favoring enforcement, the lack of evidence from the Defendant regarding his business or the impact of removing the exception, and the absence of explanation for misappropriated funds, it is inappropriate to retain the Angel Bell exception in the WFO. The exception is therefore deleted.

Parties
Claimant: Lenkor Energy Trading DMCC; Defendant: Irfan Iqbal Puri
Jurisdiction
England and Wales
Judgment Date
09 August 2022
Procedural Posture
Commercial Court Application (post Judgment) / Application to Vary Worldwide Freezing Order (wfo) by Removing 'angel Bell' Exception
Outcome
Application granted
Legal Topics
Worldwide Freezing Orders, Post Judgment Mareva Injunctions, Angel Bell Exception, Enforcement of Foreign Judgments
Civil Procedure Commercial Law Enforcement of Judgments Worldwide Freezing Orders Post Judgment Mareva Injunctions Angel Bell Exception Enforcement of Foreign Judgments

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Parties

Lenkor Energy Trading DMCC

Claimant

Irfan Iqbal Puri

Defendant

Procedural Posture

Commercial Court Application (post Judgment) / Application to Vary Worldwide Freezing Order (wfo) by Removing 'angel Bell' Exception

Legal Issues

  1. 1 Whether the 'Angel Bell' exception should be removed from the worldwide freezing order post-judgment
  2. 2 Whether the Defendant provided sufficient evidence to justify retention of the exception
  3. 3 Whether the circumstances justify continued protection for the Defendant's business activities

Ratio Decidendi

Given the entry of an English judgment, the law's policy favoring enforcement, the lack of evidence from the Defendant regarding his business or the impact of removing the exception, and the absence of explanation for misappropriated funds, it is inappropriate to retain the Angel Bell exception in the WFO. The exception is therefore deleted.

Court Disposition

Application granted

Orders

  • The worldwide freezing order is varied to delete clause 11(b) (the Angel Bell exception).
  • The Defendant may apply to reimpose the exception with fuller evidence.