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England and Wales Case Law

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Commercial law

DBLP Sea Cow Limited v Lars Steffenson

The High Court granted an interim proprietary injunction over shares or sale proceeds, finding a serious issue over trust, urgency, and no adequate damages remedy.

  • Proprietary injunction
  • Trusts
  • Clean hands doctrine
  • Contract variation
  • Freezing orders
  • Interim-injunctions
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Equity [2025] EWHC 2732 (Ch)

DBLP Sea Cow Ltd v Steffenson

DBLP Sea Cow Ltd v Steffenson [2025] EWHC 2732 (Ch) (02 October 2025)

The High Court granted a holding proprietary injunction over shares or their sale proceeds in a dispute over whether a 16 May 2025 SPA created a trust.

  • Proprietary injunction
  • Breach of trust
  • Share sale dispute
  • Clean hands doctrine
  • Interim relief
  • Proprietary-injunction
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Insolvency [2025] EWHC 2069 (Ch)

IAHP Group Holdings Lt, Re

IAHP Group Holdings Lt, Re [2025] EWHC 2069 (Ch) (04 August 2025)

The High Court granted a without-notice proprietary injunction, worldwide freezing order, and disclosure order in a liquidation misfeasance claim against two former directors.

  • Directors' duties
  • Misfeasance
  • Proprietary injunction
  • Freezing order
  • Constructive trust
  • Disclosure order
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Private international law

Loudmila Bourlakova & Ors v The Estate of Oleg Bourlakov & Ors

The court considered jurisdiction, summary judgment and injunction applications concerning ownership of Panamanian bearer-share companies and related asset control.

  • Subject matter jurisdiction
  • Bearer shares
  • Panamanian corporate law
  • Proprietary injunction
  • Asset freezing
  • Abuse of process
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Company law

David Victor Garofalo v David Adrian Crisp & Anor

The High Court granted a proprietary injunction over Seboni profits, refused a freezing order, and allowed targeted information and preservation orders in a shareholder unfair prejudice dispute.

  • Proprietary injunction
  • Freezing order
  • Disclosure of information
  • Fiduciary duties
  • Unfair prejudice
  • Preservation of evidence
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Company law [2025] EWHC 966 (Ch)

Garofalo v Crisp & Anor (Re Valorem Holdings Ltd)

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.

  • Unfair prejudice
  • Proprietary injunction
  • Freezing order
  • Disclosure of information
  • Fiduciary duties
  • Constructive trust
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Insolvency

Sabrina Khan v Kevin Ashley Goldfarb

A claim for proprietary relief under sections 339 and 423 of the Insolvency Act 1986, where there is a serious issue to be tried, is sufficient to ground a proprietary injunction even if a present proprietary interest is not established. The judge did not err in law or in the exercise of discretion, and the duties of full and frank disclosure and fair presentation were adequately discharged.

  • Proprietary injunction
  • Transactions at undervalue
  • Transactions defrauding creditors
  • Duty of full and frank disclosure
  • Cross-undertaking in damages
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Insolvency

IAHP Group Holdings Limited (in Liquidation), Re

The Respondents, as directors, breached fiduciary and statutory duties by unlawfully diverting company funds for personal benefit, failed to maintain proper records, and attempted to disguise their conduct. The alleged shareholder loans are not substantiated by contemporaneous evidence and do not justify set-off. There is a real risk of asset dissipation, justifying the grant of a proprietary injunction, worldwide freezing order, and disclosure order, with a capped cross-undertaking in damages.

  • Directors' duties
  • Misfeasance
  • Proprietary injunction
  • Freezing order
  • Asset dissipation
  • Fiduciary obligations
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Commercial law [2025] EWHC 1746 (Comm)

Sachs v Snape & Ors

Sachs v Snape & Ors [2025] EWHC 1746 (Comm) (04 April 2025)

The High Court granted proprietary and freezing injunctions over alleged misappropriated cryptocurrency and funds, and permitted service out and substituted service.

  • Freezing injunction
  • Proprietary injunction
  • Fraud
  • Breach of fiduciary duty
  • Cryptocurrency
  • Jurisdiction
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England and Wales decisions are organised by court, judge, legal area and indexed issue so a practitioner can move from a proposition to a citable authority with the surrounding context intact.