Practice – Family proceedings. The wife succeeded in applications to validate service by alternative means, for judgment directly against companies on the grounds that they were mere 'ciphers' of the husband being used by him to evade the court's judgment, for orders under s 37 of the Matrimonial Causes Act 1973 and s 423 of the Insolvency Act 1986, and post-judgment freezing injunction would be extended to the companies. The Family Division found that the husband's transactions had formed part of his continuing deliberate and dishonest campaign to avoid his liabilities under a previous judgment.