Hunt v Ubhi [2023]

The provisional liquidator of a partnership had obtained a freezing order against its partners. The provisional liquidator gave a cross-undertaking in damages limited to the net realisations in the insolvent estate. Christopher Brockman and Phillip Gale acted for the provisional liquidator on the appeal but not below. The Court of Appeal gave guidance on the circumstances in which it may be appropriate for the court to accept a limited cross-undertaking. Consideration was also given to the powers of a provisional liquidator of a partnership to apply for freezing orders.