Golden Sphinx Limited v Itkin (Royal Court : Hearing (Civil) : Cadin : Companies) [2026] JRC 061 (18 February 2026)

Golden Sphinx Limited v Itkin (Royal Court : Hearing (Civil) : Cadin : Companies) [2026] JRC 061 (18 February 2026)

The court determined that the reasonable and likely recoverable costs for discovery and instructing a new Jersey advocate amount to £431,187.88, based on a reduced blended hourly rate and the use of technology assisted review, with existing costs orders to be set off and the balance to be paid into court. Security for costs is not to be used to provide a war chest or leverage for representation, but to protect against the risk of non-recovery if the plaintiff's claim fails.

Citation
[2026] JRC 061
Parties
Plaintiff: Golden Sphinx Limited; Defendant: Mr Itkin
Jurisdiction
Jersey
Judgment Date
18 February 2026
Procedural Posture
Civil / Interlocutory Application for Security for Costs
Outcome
Application granted in part
Legal Topics
Security for Costs, Discovery, Costs Recovery, Cross Jurisdictional Litigation
Civil Procedure Company Law Insolvency Security for Costs Discovery Costs Recovery Cross Jurisdictional Litigation

Case Brief

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Parties

Golden Sphinx Limited

Plaintiff

Mr Itkin

Defendant

Procedural Posture

Civil / Interlocutory Application for Security for Costs

Legal Issues

  1. 1 What is the appropriate amount of security for costs to be ordered in favour of the defendant?
  2. 2 Should the amount claimed by the defendant be reduced to reflect reasonable and likely recoverable costs?
  3. 3 Can outstanding costs orders be set off against the security for costs to be provided?

Ratio Decidendi

The court determined that the reasonable and likely recoverable costs for discovery and instructing a new Jersey advocate amount to £431,187.88, based on a reduced blended hourly rate and the use of technology assisted review, with existing costs orders to be set off and the balance to be paid into court. Security for costs is not to be used to provide a war chest or leverage for representation, but to protect against the risk of non-recovery if the plaintiff's claim fails.

Court Disposition

Application granted in part

Orders

  • Security for costs fixed at £431,187.88, comprising £281,187.88 for discovery and £150,000 for new advocate to read in.
  • Enforcement of existing costs orders in favour of the plaintiff (£234,936.34) stayed and set off against the security for costs until further order.