Insolvency – Petition. The Court of Appeal, Civil Division, held that a validation order in respect of a payment made to a creditor after a winding up petition had been made should only be made in relation to dispositions occurring after presentation of winding-up petition if there was some special circumstances that showed that the disposition in question would be, in a prospective application case, or had been, in a retrospective application case, for the benefit of the general body of unsecured creditors, such that it was appropriate to disapply the usual pari passu principle.