Cedar Mundi (Holding) SAL v Attieh & Ors [2025] EWHC 1930 (Comm) (25 July 2025)

Cedar Mundi (Holding) SAL v Attieh & Ors [2025] EWHC 1930 (Comm) (25 July 2025)

Security for costs is ordered against the claimant because, although the Crabtree principle applies due to overlapping claims and counterclaims, the Dumrul undertaking offered by the Defendants neutralises the risk of injustice. Discretionary factors, including the relative lateness of the application and the...

Source-derived case information.

Citation
[2025] EWHC 1930 (Comm)
Parties
Claimant: Cedar Mundi (Holding) SAL; Defendant: Mr Bassel Attieh; Defendant: Mr Talal Al Bahar; Defendant: IFA Capital Ltd; Defendant: Med Al Bahar International Ltd; Defendant: Cedar II Fund LP
Jurisdiction
England and Wales
Judgment Date
25 July 2025
Procedural Posture
Security for Costs Application in Consolidated Commercial Proceedings / Interlocutory Application Prior to Trial
Outcome
Application granted in part
Legal Topics
Security for Costs, Jurisdiction, Declaratory Relief, Fraud Allegations, Enforcement of Judgments
Civil Procedure Commercial Law Security for Costs Jurisdiction Declaratory Relief Fraud Allegations Enforcement of Judgments

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Parties

Cedar Mundi (Holding) SAL

Claimant

Mr Bassel Attieh

Defendant

Mr Talal Al Bahar

Defendant

IFA Capital Ltd

Defendant

Med Al Bahar International Ltd

Defendant

Cedar II Fund LP

Defendant

Procedural Posture

Security for Costs Application in Consolidated Commercial Proceedings / Interlocutory Application Prior to Trial

Legal Issues

  1. 1 Whether security for costs should be ordered against the claimant under CPR 25.13 and 25.27
  2. 2 Whether the Crabtree principle precludes security for costs in light of overlapping claims and counterclaims
  3. 3 Whether a Dumrul undertaking neutralises the Crabtree principle

Ratio Decidendi

Security for costs is ordered against the claimant because, although the Crabtree principle applies due to overlapping claims and counterclaims, the Dumrul undertaking offered by the Defendants neutralises the risk of injustice. Discretionary factors, including the relative lateness of the application and the claimant's asset position, do not justify refusing or limiting security. The Defendants are entitled to security for their costs, subject to quantum adjustments for incurred costs and discounts already applied.

Court Disposition

Application granted in part

Orders

  • Security for costs ordered against the claimant in favour of all defendants, subject to quantum adjustments for incurred costs and discounts.
  • Security to be provided within a specified period; failure to do so will result in dismissal of the claim and counterclaims as per the Dumrul undertaking.