Richard Sandor Frischmann v Vaxeal Holdings SA & Ors

Richard Sandor Frischmann v Vaxeal Holdings SA & Ors

The applicant failed to satisfy the court that he met the financial eligibility criteria under CPR 52.14(1)(a) due to his refusal to comply with asset disclosure and cross-examination orders, leading to the inference that he has undisclosed assets. Therefore, the court's power to order a transcript at public expense did not arise.

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 / Application for Transcript at Public Expense Following Dismissal of Application to Vary Passport Order
Outcome
Application refused
Legal Topics
Transcripts at Public Expense, Judgment Debtor Asset Disclosure, Passport Orders, Appeal Procedure
Civil Procedure Enforcement of Judgments Transcripts at Public Expense Judgment Debtor Asset Disclosure Passport Orders Appeal Procedure

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Parties

Richard Sandor Frischmann

Claimant

Vaxeal Holdings SA

Defendant

IDM Ventures Limited

Defendant

Christopher Samuelson

Defendant

Procedural Posture

Civil / Application for Transcript at Public Expense Following Dismissal of Application to Vary Passport Order

Legal Issues

  1. 1 Whether the applicant qualifies for a transcript of the proceedings or judgment at public expense under CPR 52.14

Ratio Decidendi

The applicant failed to satisfy the court that he met the financial eligibility criteria under CPR 52.14(1)(a) due to his refusal to comply with asset disclosure and cross-examination orders, 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