The Court of Appeal handed down judgment on Wednesday, 19th April 2023, in Hunt v Ubhi [2023] EWCA Civ 417, in which it reiterated that the default rule is that applicants for freezing orders, including office holders, must provide unlimited cross undertakings in damages and that a departure from the default rule must be justified.

John Machell KC and Dan McCourt Fritz KC, in his last appearance as a junior, acted for the successful appellant. The decision also flags, but does not resolve, some niche issues relating to the Insolvent Partnerships Order.

The judgment can be viewed here.