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England and Wales decisions
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Post-judgment security for costs application partly refused and partly granted, with security ordered only for detailed assessment proceedings.
Hughes v Bellamy & Ors [2026] EWHC 237 (Ch) (15 January 2026)
The High Court granted a short interim injunction preserving the assets of two companies pending an Isle of Man unfair prejudice dispute.
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.
The husband's failure to attend, provide disclosure, and comply with orders, combined with evidence of asset transfers and continued luxurious lifestyle, demonstrates he has the means to pay. The E country asset freeze does not affect assets outside E country. Maintenance and legal services payment orders are enforced, undertakings converted to orders, and freezing order granted to preserve assets.
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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.
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 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.
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Mahtani v Mahtani [2025] EWFC 35 (Fam) (16 January 2025)
In a financial remedies claim after divorce, the court drew adverse inferences from the husband’s complete non-disclosure and awarded the wife £13.9 million, with a freezing order continued.
The High Court ordered the respondent to pay the costs of a freezing order application, substituted service, and the return hearing, applying Dos Santos to interlocutory costs.
The mother is entitled to a legal services payment order, subject to a 15% deduction for notional detailed assessment, due to her lack of means and the father's significant undisclosed wealth. A freezing order and property restriction are justified due to evidence of asset dissipation and risk to the applicant's claim. Directions are given to progress the Schedule 1 claim.
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