Catalyst Management Services v Libya Africa Investment Portfolio

Practice – Strike out. Given that no satisfactory evidence had been given of the alleged concluded funding agreement, the judge had been entitled to find that the appellant had failed to establish a change in circumstances warranting the setting aside of an order to provide security for costs. The Court of Appeal, Civil Division, in dismissing the appellant's appeal, further held that the judge had clearly engaged with the misstatement case, because he had rejected it on the basis that, on the evidence, there had been no reasonable grounds for the misstatement.

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