Brewer Management Corporation v Christie Manson & Woods (Master Pester, 30 January 2026)

In Brewer Management Corporation v Christie Manson & Woods Master Pester refused to grant security for costs against a claimant company incorporated in the British Virgin Islands. Master Pester held that the gateways for security were established but that security should nevertheless be refused because ordering security would have the effect of granting the defendant security for the costs of its counterclaim. This is a modern application of the so-called ‘Crabtree Principle’ established by the Court of Appeal in BJ Crabtree (Insulations) Ltd v GPT Communication Systems Ltd (1990) 59 BLR 43.

The wider proceedings concern a dispute over a 'third-party guarantee’ of a Picasso painting sold by Christie’s at auction.

The claimant was represented by Ricky Diwan KC, leading Harry Martin of Serle Court, and instructed by Tim Maxwell, Elizabeth Scandrett and Matthew Shore of Wedlake Bell.

The judgment can be read in full here.