Practice – Pre-trial or post-judgment relief. The first defendant was the beneficial owner of a property, despite a transfer of the legal title to the interested party in the proceedings. The Chancery Division held that there had been a presumption of a resulting trust where the transfer had been gratuitous and that that presumption had not been displaced by on the facts. In those circumstances, and where the claimant National Crime Agency had obtained summary judgement against the first defendant concerning unpaid tax, an interim charging order was made final.