Costs

It was established law that: (i) it was the purpose of a freezing order to stop the injuncted defendant dissipating or disposing of property which could be the subject of enforcement if the claimant went on to win the case it had brought, and not to give the claimant security for his claim; (ii) the jurisdiction to make a freezing order should be exercised in a flexible and adaptable manner so as to be able to deal with new situations and new ways used by sophisticated and wily operators to make themselves immune to the courts' orders or deliberately to thwart the effective enforcement of those orders; and (iii) because of the penal consequences of breaching a freezing order and the need of the defendant to know where he, she or it stood, such orders should be clear and unequivocal and should be strictly construed. Further, there was tension between the first two principles and the third because a strict construction of the order might leave it open to an unscrupulous and