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England and Wales decisions
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The Commercial Court granted Nexedge permission to enforce a cross-undertaking in damages after a freezing injunction was discharged as wrongly obtained.
The worldwide freezing injunction was discharged because the claimant failed to meet the duty of full and frank disclosure, did not fairly present material facts, and did not establish a real risk of asset dissipation. The property in question was not under the defendant's control, and the claimant's representations were misleading. The notice requirements under CPR were not properly satisfied, and the order extended beyond what was justified by the evidence.
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McKenzie v First Greater Western Ltd (t/a Great Western Railway) [2026] EWHC 868 (KB) (17 April 2026)
The High Court refused an interim injunction to stop an employer’s disciplinary hearing, holding the employee’s complaints should be pursued within the disciplinary process and appeal.
Petrichor Energy FZCO v Bashar & Anor [2026] EWHC 914 (Comm) (30 March 2026)
The High Court granted a post-judgment worldwide freezing order and alternative service by email, finding a good arguable case of asset dissipation risk.
ZAB v Persons Unknown [2026] EWHC 669 (KB) (19 March 2026)
The High Court continued an interim injunction after a ransomware exfiltration, allowed retrospective alternative service by email, abridged time, and continued anonymity.
There is no principled reason to refuse inclusion of a penal notice in the sealed order; amendments to CPR 81 reverse the Taray Brokering decision and clarify that a penal notice is a warning notice added as necessary.
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VTB Bank PJSC v Kuanyshev & Anor [2026] EWHC 591 (Comm (16 March 2026)
The Commercial Court refused to raise the freezing order disclosure threshold, increased fortification of the cross-undertaking to £500,000 paid into Court, and kept references to a third party and property in issue pending a preliminary issue trial.
The Commercial Court refused to raise a freezing-order disclosure threshold, but increased fortification of the cross-undertaking and ordered payment into Court.
Allen v Stuart & Anor (Addendum Judgment) [2026] EWHC 664 (KB) (11 March 2026)
The High Court held that a penal notice could be included in the sealed order recording undertakings, and that current CPR 81 permits its addition at a party’s request.
Aksahin v London Borough of Enfield [2026] EWCA Civ 231 (06 March 2026)
The Court of Appeal dismissed a challenge to contempt findings arising from anti-social car cruising, upholding liability, costs, and a suspended committal order.
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