Frischmann v Vaxeal Holdings SA & Ors [2026] EWHC 694 (Ch) (24 March 2026)

Frischmann v Vaxeal Holdings SA & Ors [2026] EWHC 694 (Ch) (24 March 2026)

The applicant failed to satisfy the court that he lacked means as required by CPR 52.14(1)(a), given his refusal to comply with orders for asset disclosure and cross-examination, leading to the inference that he has undisclosed assets. Therefore, the court's power to order a transcript at public expense did not arise.

Citation
[2026] EWHC 694 (Ch)
Parties
Claimant: Richard Sandor Frischmann; Defendant: Vaxeal Holdings SA; Defendant: IDM Ventures Limited; Defendant: Christopher Samuelson
Jurisdiction
England and Wales
Judgment Date
24 March 2026
Procedural Posture
Civil / Post Judgment Application for Transcript at Public Expense
Outcome
Application refused
Legal Topics
Transcripts at Public Expense, CPR 52.14, Asset Disclosure, Cross Examination of Judgment Debtor
Civil Procedure Enforcement of Judgments Transcripts at Public Expense CPR 52.14 Asset Disclosure Cross Examination of Judgment Debtor

Case Brief

Summary, issues, holding and outcome

More case intelligence is available

Unlock the full research layer for this judgment.

Full judgment text Downloadable case file Legal principles 1 Authorities cited 1 Party arguments 2 Amounts and remedies 3
Sign in to unlock

Parties

Richard Sandor Frischmann

Claimant

Vaxeal Holdings SA

Defendant

IDM Ventures Limited

Defendant

Christopher Samuelson

Defendant

Procedural Posture

Civil / Post Judgment Application for Transcript at Public Expense

Legal Issues

  1. 1 Whether the applicant qualifies for a transcript at public expense under CPR 52.14
  2. 2 Whether the applicant has demonstrated lack of means and necessity in the interests of justice

Ratio Decidendi

The applicant failed to satisfy the court that he lacked means as required by CPR 52.14(1)(a), given his refusal to comply with orders for asset disclosure and cross-examination, leading to the inference that he has undisclosed assets. Therefore, the court's power to order a transcript at public expense did not arise.

Court Disposition

Application refused

Orders

  • Request for transcript of entire proceedings at public expense refused
  • Request for transcript of judgment at public expense refused