The 'interest' requirement for costs orders against non-parties under Knight v FP Special Assets Limited is not confined to financial interest; a non-party's environmental or activist interest in the subject matter of litigation may be sufficient. Prior notice to a non-party of a potential costs application is not an absolute prerequisite. Where security for costs has been sought and obtained but not provided, a costs order against the non-party driving the litigation remains available as an additional remedy.
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