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England and Wales decisions
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Gable Insurance AG v Dewsall & Ors [2025] EWCA Civ 884 (11 July 2025)
The Court of Appeal upheld a domestic freezing order against Judith Dewsall, confirmed she could not fund legal fees from Weald Hall proceeds, and dismissed the remaining appeal grounds.
Lime Technology Ltd v Liverpool City Council [2025] EWHC 1654 (TCC) (01 July 2025)
The High Court allowed Lime Technology access to a confidentiality ring including a client representative, despite objections over Bolt’s sensitive pricing data.
The High Court decided costs after an ex parte freezing order and later consent resolution, apportioning costs between HMRC and the respondents.
Nobel Oil E&P North Sea Ltd, R (On the Application Of) v Oil Gas Authority (t/a North Sea Transition Authority) [2025] EWHC 1280 (Admin) (01 May 2025)
The High Court held it had jurisdiction to stay an interlocking decommissioning process, but refused relief because Nobel Oil would not give a cross-undertaking in damages.
Garofalo v Crisp & Anor (Re Valorem Holdings Ltd) [2025] EWHC 966 (Ch) (16 April 2025)
The High Court granted a proprietary injunction over Seboni brand profits and limited information orders, but refused a freezing order as unnecessary and disproportionate.
The court refused to grant permission for the sale of the aircraft at this stage due to unresolved concerns about the independence of the purchaser, the adequacy and independence of the valuation and marketing process, and the significant reduction in value from previous valuations. The evidence did not sufficiently demonstrate that the transaction was at a proper market value or that the purchaser was independent. The application could be reconsidered if a proper independent valuation or higher offer is produced.
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Given the respondent's failure to comply with disclosure obligations, evidence of undisclosed WhatsApp messages, deletion of laptop data after litigation was contemplated, and the real risk of concealment or destruction of relevant documents, an imaging order is justified and proportionate. The order is limited to the minimum necessary to preserve evidence, with appropriate safeguards for privacy and privilege.
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The claimants failed to establish a good arguable case that the US$1 million Series E investment was recoverable as either a direct or consequential loss resulting from the alleged deceit. The pleadings and evidence did not show that the Series E investment was induced by or causally connected to the alleged misrepresentations. The freezing injunction continues, but the application to increase the enjoined sum is dismissed.
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Gallahue & Ors v Tripathi & Anor [2024] EWHC 1740 (Ch) (05 July 2024)
The High Court refused to increase a freezing order by US$1 million, holding the claimants had not shown a good arguable case that the later investment was recoverable as consequential loss.
The application is adjourned to allow the defendants notice and an opportunity to respond, as procedural fairness requires both sides to be heard before substantive orders are made.
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