Grigori Fishman v Viktor Mangazeev
The Fancourt order established a regime permitting payment of living expenses from frozen assets, with quantum to be determined by the court or agreement. There is no requirement for further worldwide asset disclosure or historical funding evidence before such payments. The claimant's attempt to impose such requirements constitutes an attempt to reopen matters already decided, contrary to the Chanel principle. The court's task is to determine the quantum based on evidence provided, applying healthy scepticism but not requiring additional disclosure.
- Parties
- Claimant: Grigori Fishman; Defendant: Viktor Mangazeev
- Jurisdiction
- England and Wales
- Judgment Date
- 21 May 2025
- Procedural Posture
- Civil / Post Freezing Order, Determination of Living Expenses Exception
- Outcome
- Application granted in part; quantum of living expenses determined subject to provision of relevant information and confirmations.
- Legal Topics
- Freezing Orders, Exceptions to Injunctions, Disclosure of Assets, Living Expenses, Quantification of Exceptions
Case Brief
Summary, issues, holding and outcome
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Parties
Grigori Fishman
Claimant
Viktor Mangazeev
Defendant
Procedural Posture
Civil / Post Freezing Order, Determination of Living Expenses Exception
Legal Issues
- 1 Whether the defendant is entitled to pay living expenses from frozen assets without further worldwide asset disclosure
- 2 Determination of quantum for living expenses exception under a freezing order
Ratio Decidendi
The Fancourt order established a regime permitting payment of living expenses from frozen assets, with quantum to be determined by the court or agreement. There is no requirement for further worldwide asset disclosure or historical funding evidence before such payments. The claimant's attempt to impose such requirements constitutes an attempt to reopen matters already decided, contrary to the Chanel principle. The court's task is to determine the quantum based on evidence provided, applying healthy scepticism but not requiring additional disclosure.
Court Disposition
Application granted in part; quantum of living expenses determined subject to provision of relevant information and confirmations.
Orders
- Defendant may pay rent, school fees, and household expenses from frozen assets, subject to providing unredacted tenancy agreement to claimant's legal team and confirmation regarding school invoices.
- No order as to costs.
Full Case Text
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